Forbes has published an article, “Conservation Easement Syndicates Outlawyering IRS”, which discusses king made certain syndicated conservation easement transactions “listed transactions”. The article begins as follows:
The full Tax Court in one of its regular decisions (Green Valley Investors LLC) has dealt a blow against the IRS in its struggle with abusive syndicated conservation easements. A key IRS move in the fight was Notice 2017-10 which made certain syndicated conservation easement transactions “listed transactions”.
The reporting regime that listed transactions are subject to is so intimidating and the penalties so nasty that they inspired Reilly’s Fourteenth Law of Tax Planning – If something is a listed transaction, just don’t do it. Of course, the listing requirement was not enough to stop the syndicated conservation easement (SCE) industry. Thanks to the Green Valley decision, Notice 2017-10 may no longer be a problem as the Tax Court ruled that the IRS did not jump through the right hoops in issuing it.
Click here to see the full article: “Conservation Easement Syndicates Outlawyering IRS”
Posted by Marin Larkin, Associate Editor, Wealth Strategies Journal.
Wealth Strategies Journal 