In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Judge Batten, Chief United States District Judge for the Northern District of Georgia, handed down lengthy sentences in the first-of-its-kind criminal trial related to syndicated conservation easements (“SCEs”). On January...more
1/22/2024
/ Conservation Easements ,
CPAs ,
Criminal Prosecution ,
Department of Justice (DOJ) ,
Enforcement Actions ,
Fraud ,
Government Investigations ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
SCE ,
Tax Deductions ,
Tax Liability
After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more
3/14/2023
/ Bittner v United States ,
FBAR ,
Foreign Bank Accounts ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Offshore Funds ,
Reporting Requirements ,
SCOTUS ,
Tax Liability ,
Tax Penalties ,
Tax Returns
Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
1/12/2023
/ Charitable Donations ,
Conservation Easements ,
Federal Budget ,
Internal Revenue Code (IRC) ,
IRS ,
Pass-Through Entities ,
Regulatory Reform ,
Tax Deductions ,
Tax Liability ,
Tax Planning ,
Tax Reform
As the IRS and the Department of Justice continue to focus enforcement efforts on conservation easements, the Supreme Court has been asked to settle a dispute regarding the validity of the “protected in perpetuity”...more
Earlier this year, the Department of Justice filed the first criminal indictment of promoters, appraisers and accountants connected to an alleged scheme to create syndicated conservation easements. The move followed increased...more