STEVEN TOSCHER, MICHEL STEIN and SANDRA BROWN to Speak at Upcoming Strafford Webinar
Posted by Hochman Salkin Toscher Perez P.C. 
Posted on Friday, October 06, 2023
We are pleased to announce that Steven Toscher, Michel Stein, and Sandra Brown will be speaking at the upcoming Strafford webinar “Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions” Tuesday, October 10, 2023, 10:00 a.m. – 11:30 a.m. (PST).
The IRS has significantly increased enforcement actions for syndicated conservation easements. This crackdown on conservation easement transactions forces taxpayers, tax counsel, and advisers to identify and recognize key tax issues in structuring these transactions.
A conservation easement is a legally enforceable perpetual land preservation agreement between a landowner and either a government agency or a qualified land protection organization (such as a land trust) for the conservation of the land and its resources. Grantors within these transactions can take advantage of significant tax benefits so long as the easement meets IRS approval where there is a donation.
Typically, charitable deductions are not allowed for these transactions, but IRC Sections 170(h)(1) through (h)(5) and Treas. Reg. 1.170A-14 provide for an exception. A charitable contribution deduction is allowed
Typically, charitable deductions are not allowed for these transactions, but IRC Sections 170(h)(1) through (h)(5) and Treas. Reg. 1.170A-14 provide for an exception. A charitable contribution deduction is allowed for the fair market value of the conservation easement donated to certain charitable organizations, subject to a limitation on the amounts.
Limitations on the deduction lead to the setup of syndications to purchase land for the conservation easements. This results in high deductions for taxpayers and heightened scrutiny by the IRS.
The panel will review these and other crucial issues:
- What are the key tax considerations for structuring conservation easements?
- What are the income regulations applicable to conservation easement transactions?
- What factors are considered by the IRS in reviewing conservation easement transactions?
- How can taxpayers and their counsel effectively defend and litigate conservation easement tax issues?
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