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Charitable Donations Internal Revenue Service Tax Liability

Farella Braun + Martel LLP

REFRESH: Loot and Private Foundation Rules – Part 2

Welcome to EO Radio Show - Your Nonprofit Legal Resource. In this episode, we refresh EO Radio Show episode 22, the second of our two episodes exploring private foundation rules using commentary on the comic Apple TV+ series...more

Cadwalader, Wickersham & Taft LLP

Getting Technical with Partnership Termination Rule

The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more

Polsinelli

Tax Court Strikes out Smoltz and Klesko’s Big K SCE, but Provides Relief for Those Facing Fraud Allegations

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In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more

Foodman CPAs & Advisors

Estrategias Y Esquemas Tributarios Para Evitar Impuestos A La Vanguardia Del IRS

El 11/04/24, el IRS concluyó su Lista de la Docena Sucia de 2024 con una “advertencia a los contribuyentes sobre los promotores que venden estrategias fiscales falsas y esquemas extraterritoriales fraudulentos diseñados para...more

Foodman CPAs & Advisors

Tax Strategies And Schemes To Avoid Taxes At IRS Forefront

On 4/11/24, the IRS wrapped up its 2024 Dirty Dozen List with a “warning to taxpayers regarding promoters selling bogus tax strategies and fraudulent offshore schemes designed to reduce or avoid taxes altogether”. Tax...more

Holland & Knight LLP

Not So Cryptic: IRS Increases Oversight on Cryptocurrency Income Tax Reporting Requirements

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Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more

Polsinelli

Easement Fund Victory on Perpetuity Will Result in More Attention on Valuation

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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

Foodman CPAs & Advisors

Individuos De Alto Patrimonio Reciben Advertencia Del IRS

El 10 de abril de 2024, como parte de su campaña de la Docena Sucia (“Dirty Dozen”) para 2024, el IRS emitió una advertencia a individuos de alto patrimonio con respecto a tres trampas fiscales diseñadas para ellos por...more

Foodman CPAs & Advisors

High Net Worth Individuals Get Warning From IRS

On 4/10/24, as part of its Dirty Dozen Campaign for 2024, the IRS issued a warning to High Net Worth Individuals regarding three tax traps designed for them by dishonest promoters and shady tax practitioners. High Net Worth...more

Farella Braun + Martel LLP

Nonprofit Quick Tip: State Filings in North Carolina and South Carolina

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Episode 75 is the tenth in a series of Quick Tip episodes focusing on the details of state registration of nonprofit corporations. Today, Cynthia Rowland and Joe...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

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Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Gray Reed

The Fine Print: IRS Examination of Artwork

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Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased focus on auditing...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Private Foundation Advocacy

Welcome to EO Radio Show - Your Nonprofit Legal Resource. Here we are, solidly in the 2024 election year, and that means that private foundations need to refresh their understanding of election year issues for organizations...more

Farella Braun + Martel LLP

REFRESH Nonprofit Basics: Election Year Issues for Private Foundations and Public Charities - Legislative Lobbying and Advocacy...

Welcome to EO Radio Show - Your Nonprofit Legal Resource. As most listeners are undoubtedly aware, 2024 is an election year, and that means that charities and private foundations need to refresh their understanding of...more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

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On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Polsinelli

Slogans and Insults: Fisher Defendants Respond to the Government’s Novel Conservation Easement Case

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Last week, the first federal criminal trial related to syndicated conservation easement (“SCE”) deals began with impaneling the jury and opening statements. Each of the Fisher defendants on trial, Jack Fisher, James Sinnott,...more

Freeman Law

Treat People With Kindness (But Don’t Forget Secular Tax Law)

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For tax-exempt public charities, benevolent acts must be considered within the guardrails of section 501(c)(3) of the Internal Revenue Code. To enjoy tax-exemption as an organization described in Section 501(c)(3), the...more

Freeman Law

Tax Court in Brief | Estate of Hoenshied v. Commissioner | Anticipatory Assignment of Income, Charitable Contribution Deduction,...

Freeman Law on

Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more

Freeman Law

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of...

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Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more

Freeman Law

Tax Court in Brief | Lim v. Comm'r | Disallowance of Charitable Contribution Deduction for Lack of Qualified Appraisal; Reasonable...

Freeman Law on

Summary:  This case involves taxpayers, Calvin Lim and Helen Chu (together, “Petitioners”) federal income tax liabilities for 2016 and 2017 with respect to a disallowed charitable contribution deduction....more

Freeman Law

IRS CCMs on Crypto Donations and Crypto Losses

Freeman Law on

IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition - Introduction - The IRS recently released two chief counsel...more

Polsinelli

$1.7 Trillion Spending Bill Drops the Hammer on Conservation Easements

Polsinelli on

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

Freeman Law

Tax Court in Brief | Brooks v. Comm’r | Charitable Contribution Deductions for Conservation Easement; Contemporaneous Written...

Freeman Law on

Tax Litigation:  The Week of December 19th, 2022, through December 23rd, 2022 Starer v. Comm’r, T.C. Memo. 2022-124 | December 20, 2022 |Wells, J. |Docket No. 615-13 Mamadou v. Comm’r, T.C. Memo. 2022-121 | December 20, 2022...more

Freeman Law

Correction to APA Non-Compliance | IRS Issues Proposed Regulations for Syndicated Conservation Easements

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On December 6th, the IRS proposed regulations (and comment period for same) that would require participants and promoters of syndicated conservation easement transactions to make certain disclosures relating conservation...more

Polsinelli

SCOTUS Could Vacate Conservation Easement Regulations

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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

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