The Presumption of Innocence Podcast: Episode 21 - Conservation Easement Donations: Tax Shelter or Charitable Contribution Deduction?
Jones Day Presents: Strategies for Dealing with IRS Appeals: When Exam Attends the Appeals Conference
Jones Day Presents: Strategies for Dealing with the IRS: Going to Court
Jones Day Presents: Strategies for Dealing with the IRS: The IRS Appeals Office
If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more
In a case that will be of interest to all developers and funders of UK infrastructure and energy projects, Orsted West of Duddon Sands v HMRC [2025] (previously known as Gunfleet Sands v HMRC), the Court of Appeal held that...more
A recent case decided by the United States Court of Appeals of the Tenth Circuit reminds taxpayers to be aware that the Internal Revenue Service (IRS) is not necessarily locked in to the positions and arguments stated in the...more
The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation...more