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
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
11/16/2022
/ Administrative Procedure Act ,
Charitable Deductions ,
Conservation Easements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investment ,
IRS ,
Partnerships ,
Tax Avoidance ,
Tax Court ,
Tax Deductions ,
Tax Penalties ,
Tax Planning
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
Last week the Ninth Circuit issued a win for taxpayers in US v. Boyd, limiting penalties for non-willful violations of the requirement to file a Report of Foreign Bank and Financial Accounts (FBAR). ...more
4/5/2021
/ Failure-to-File ,
FBAR ,
Foreign Financial Accounts ,
Income Taxes ,
IRS ,
Offshore Funds ,
OVDP ,
Regulatory Violations ,
Reporting Requirements ,
Tax Evasion ,
Tax Penalties ,
Tax Planning