Taxes

Judge David Gustafson injected a good dose of common sense into the ongoing struggle between the IRS and the syndicators of conservation easements. His opinion in Mill Road 36 Henry LLC lays bare the nonsense that has created the syndicated conservation easement industry. The story starts with undeveloped suburban land acquired by real estate professionals
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Sometimes, good things can come from adversity. During the pandemic, the IRS had no choice but to begin to move towards new technologies—including accepting digital signatures. Now, the IRS has announced that it is extending “certain temporary flexibilities.” Specifically, they will accept digital signatures “indefinitely until more robust technical solutions are deployed.” Additionally, the agency
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There is nothing inherently wrong with forming and utilizing a charitable remainder annuity trust (“CRAT”) for tax-planning purposes; people do it all the time. Issues arise, though, when taxpayers claim positions generating benefits that arguably exceed those contemplated by Congress and the Internal Revenue Service (“IRS”). When this occurs, enforcement actions begin, and participating taxpayers
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In the second of a two-episode series, Tim Jacobs of Hunton Andrews Kurth continues his discussion of the energy credits enacted in the Inflation Reduction Act and the proposed regulations. This transcript has been edited for length and clarity. David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax Notes
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Many people are baffled about the status of conservation easement donations, which is logical given all that has happened recently. Among other things, courts ruled that the IRS violated the law when calling certain things as “listed transactions,” the IRS tried to salvage the situation by issuing Proposed Regulations, and Congress drastically changed the rules
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Spurring economic growth in America’s declining cities and regions has been a hard-to-achieve goal of public policy. There’s now hope that the Biden Administration’s new industrial policies, might boost growth where other efforts have failed. But the jury is still out. Industrial policy—supporting specific industries and sectors of the economy—has long been viewed skeptically by
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