Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions
Recording of a 90-minute premium CLE/CPE video webinar with Q&A
This CLE/CPE course will provide guidance to tax counsel and advisers on critical tax issues concerning conservation easement transactions. The panel will discuss critical elements in structuring conservation easement transactions to minimize IRS assessments and audits, recent IRS enforcement actions, and managing IRS examinations, as well as offer techniques in defending conservation easement transactions.
Outline
- Benefits and limitations of conservation easements
- Tax benefits for donors and applicable tax regulations
- IRS enforcement actions
- Defending and litigating conservation easement tax matters
Benefits
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?
Faculty
Sandra R. Brown
Principal
Hochman Salkin Toscher Perez
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations,... | Read More
Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.
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Michel R. Stein
Principal
Hochman Salkin Toscher Perez
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For... | Read More
Mr. Stein specializes in tax controversies, as well as tax planning for individuals, businesses and corporations. For more than 25 years, he has represented individuals with sensitive issue civil tax examinations where substantial penalty issues may arise, and extensively advised individuals on foreign and domestic voluntary disclosures regarding foreign account and asset compliance matters. Mr. Stein is well respected for his expertise and judgment in handling matters arising from the U.S. government’s ongoing enforcement efforts regarding undeclared interests in foreign financial accounts and assets, including various methods of participating in a timely voluntary disclosure to minimize potential exposure to civil tax penalties and avoiding a criminal tax prosecution referral. Mr. Stein is a frequent lecturer at national and regional conferences on topics including tax compliance sensitive issues, IRS examinations, State and Federal worker classification issues, etc.
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Steven (Steve) Toscher
Managing Principal
Hochman Salkin Toscher Perez
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions... | Read More
Mr. Toscher has been representing clients for more than 35 years before the Internal Revenue Service, the Tax Divisions of the U.S. Department of Justice and the Office of the United States Attorney, numerous state taxing authorities and in federal and state court litigation and appeals. Mr. Toscher enjoys a unique combination of solid criminal defense experience and extensive substantive tax experience to assist individuals and entities subject to sensitive government inquiries. He has considerable experience as lead counsel in defending criminal tax fraud investigations (both administrative and grand jury investigations) as well as in defending criminal tax prosecutions (both jury and non-jury). Mr. Toscher’s tax practice includes a wide array of substantive areas including income taxes, estate taxes, employment taxes, sales taxes and property taxes. He is routinely involved in sensitive issue or complex civil tax examinations and administrative appeals on behalf of wealthy individuals and their closely held entities as well as large corporations involving both domestic and foreign tax related issues.
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