IRS Final Regulations for Syndicated Conservation Easements: Impact on Structuring and Defending Easement Transactions
A live 90-minute premium CLE/CPE video webinar with interactive Q&A
This CLE/CPE course will provide tax counsel and advisers guidance on critical tax issues concerning conservation easement transactions in light of IRS final regulations. The panel will discuss critical elements of the IRS final regulations and the impact on conservation easement transactions, address IRS assessments and audits, and offer techniques for defending conservation easement transactions.
Outline
- Overview of conservation easements
- Benefits and limitations
- Applicable tax regulations
- IRS final 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 and estate tax 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?
- What risks do “Material Advisors” (CPAs, wealth managers, broker-dealers, attorneys, and other vendors) face?
- What factors should Material Advisors evaluate in order to assess their own risk?
Faculty
William J. Curtis
Senior Partner
Polsinelli
Mr. Curtis represents professionals, professional firms, and investors who are involved with or invested in Syndicated... | Read More
Mr. Curtis represents professionals, professional firms, and investors who are involved with or invested in Syndicated Conservation Easements. He helps his clients navigate the criminal, civil, and administrative risks stemming from the DOJ's and IRS's pursuit of syndicators and funds by developing and implementing innovative, cross-disciplinary strategies.
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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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Cannot Attend March 27?
Early Discount (through 02/28/25)
You may pre-order a recording to listen at your convenience. Recordings are available 48 hours after the webinar. CPE credit is not available on recordings. Strafford will process CLE credit for one person on each recording. All formats include course handouts.