Skip to content

On Sept. 13, 2021, the U.S. House Ways and Means Committee announced a proposal to limit charitable deductions for conservation easement contributions made by partnerships and other passthrough entities. The proposal, which targets syndicated conservation easement transactions, would disallow a taxpayer’s charitable contribution deduction when it exceeds 2.5 times the taxpayer’s modified basis in the passthrough entity. The proposal also addresses the application of the accuracy-related penalty and statute of limitations to conservation easement transactions. If enacted, the House proposal would make it considerably more difficult for taxpayers to prevail in cases involving conservation easement transactions.

Click here to read the full GT Alert.

Tags: charitable contributions, charitable deductions, Congress, Conservation easement, deductions, GT Insight, Internal Revenue Code (IRC), IRS
Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Michelle Ferreira Michelle Ferreira

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California

…

G. Michelle Ferreira is Co-Managing Shareholder of the San Francisco Office and Co-Managing Shareholder of the Silicon Valley Office and counsels individuals, partnerships, estates and corporations in tax disputes with the Internal Revenue Service and state and local tax agencies, including the California Franchise Tax Board, the State Board of Equalization, the Employment Development Department and county assessment appeals boards.

As a former tax litigator for the Internal Revenue Service, Michelle brings unique experience to clients who have complex and sensitive tax and penalty disputes. Michelle represents clients before the IRS, and state and local tax agencies at the audit, collection, appeals and litigation stages.

Michelle has 18 reported decisions in the U.S. Tax Court on issues such as unreported income, family limited partnerships, civil and criminal tax fraud, penalty assessments, statutes of limitation assertions, valuation disputes, controversies involving valuation discounts for lack of control and lack of marketability, tax shelters, hobby losses, complex real estate transactions, tax structured transactions, and unsubstantiated business expenses.

Read more about Michelle Ferreira
Show more Show less
Photo of Barbara T. Kaplan Barbara T. Kaplan

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals…

Barbara T. Kaplan is Co-Chair of the Global Tax Practice and has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine, and focuses her tax litigation practice on domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies and litigation, including administrative and grand jury criminal tax investigations.

Read more about Barbara T. Kaplan
Show more Show less
Photo of Courtney A. Hopley Courtney A. Hopley

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes.

…

Courtney A. Hopley represents clients in federal and state tax controversies before the IRS and the California Franchise Tax Board at the audit, collection, appeals and litigation stages. She works on tax controversy matters involving partnerships, corporations, individuals, real estate and penalty disputes. Courtney also has experience in tax planning involving entity formation, mergers and acquisitions, and reorganization transactions.

Read more about Courtney A. Hopley
Show more Show less
Related Posts
shutterstock_552445588
Syndicated Conservation Easements: Under New Fire as IRS Enforcement Action Increases
November 14, 2019
solar wind renewable energy
How the Inflation Reduction Act May Impact the Renewable Energy Industry
August 15, 2022
shutterstock_1363238018
Bipartisan Proposed Legislation Released for Qualified Opportunity Zone Investments
April 21, 2022