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Conservation Easements: IRS Enforcement and Beyond

CONSERVATION EASEMENTS: IRS ENFORCEMENT AND BEYOND

Cost Free
Presentation Length 1.0 hour

Recorded DateAugust 13, 2020
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

The IRS recently announced a significant increase in 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.  Limitations on the amount of 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. 

Our panel of tax attorneys will discuss critical elements in structuring conservation easement transactions, unique valuation issues presented in conservation easement cases, strategies to minimize IRS assessments and audits, and recent IRS enforcement actions, as well as techniques to defend conservation easement transactions.
 

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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Hochmansalkin

Steven Toscher is a principal of Hochman, Salkin, Rettig, Toscher & Perez, P.C., specializing in civil and criminal tax litigation. Mr. Toscher is a Certified Tax Specialist in Taxation, the State Bar of California Board of Legal Specialization. He maintains an active practice before the United States Tax Court, the Federal District Courts in California and Nevada, the Ninth Circuit Court of Appeals and the California State Courts. He frequently appears before the Internal Revenue Service, the California Franchise Tax Board and the California State Board of Equalization.

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Hochmansalkin

MICHEL R. STEIN is a principal at Hochman, Salkin, Rettig, Toscher & Perez, specializing in tax controversies and tax planning for individuals, businesses, and corporations. For almost 20 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. He has assisted hundreds of individuals who have complied with their foreign reporting requirements through the OVDP, Streamline, or otherwise.

Throughout his career, Mr. Stein has represented thousands of individual, business, and corporate taxpayers involved in civil examinations and administrative appeals, tax collection matters, as well as with possible assertions of fraudulent conduct and in defending criminal tax investigations and prosecutions at every administrative level within the IRS. He has litigated tax cases in the U.S. Tax Court, the U.S. District Court, and various U.S. Circuit Courts of Appeal. He continues to provide tax advice to taxpayers and their advisors around the world.

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. Mr. Stein received his LL.M. in Taxation from the NYU School of Law and graduated from the University of California, Hastings College of the Law. He gained further expertise as Attorney-Adviser to the Honorable Judge Larry L. Nameroff of the U.S. Tax Court. He is a Certified Specialist in Taxation Law by the State Bar of California, Board of Legal Specialization.

About Our Presenter

Hochmansalkin
HOCHMAN, SALKIN, RETTIG, TOSCHER & PEREZ, P.C., enjoys an unparalleled reputation for excellence and integrity in the tax community. For more than 60 years, the firm has been serving clients throughout the United States with federal and state civil tax litigation, defense of criminal tax prosecutions, all forms of tax disputes with the federal, state and local taxing authorities, white collar criminal defense, estate and business planning, and business transactions.