Conservation Easements: How to Draft and Defend Against an IRS Assault Seminar Materials

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Since 2006, courts have decided thirty-four cases challenging conservation easement donations, and reportedly 200 additional cases are in the litigation pipeline. This publication will address practical tips regarding conservation easement drafting and negotiating, as well as lessons to be learned from the recent federal tax cases and IRS guidance.

This comprehensive, stand-alone publication is direct from a February 2013 seminar. It is available as a searchable PDF via download. Click here for more information on electronic books.

CONTENT SUMMARY

Background & Developments
Section 170(h) & the Treasury Regulations
Deduction Limitations
Charitable Gift and Estate Tax Deductions
Estate Tax Exclusion
Filing a Tax Return Package to Minimize Risk of Audit: Lessons to Be Learned From Recent Tax Cases
Other Important Issues

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Table of Contents

I. Background & Developments

II. Section 170(h) & the Treasury Regulations

III. Deduction Limitations

IV. Charitable Gift and Estate Tax Deductions

V. Estate Tax Exclusion

VI. Filing a Tax Return Package to Minimize Risk of Audit:
Lessons to Be Learned From Recent Tax Cases

VII. Other Important Issues

Appendix A: Donated Conservation Easement

Appendix B: Bargain Sale Conservation Easement

Appendix C: Chart of Case Law

Appendix D: More on Conservation Purposes

Appendix E: IRS Notice 2007-50

Appendix F: IRS General Information Letter (Extinguishment)

Appendix G: IRS General Information Letter (Swaps)

Appendix H: Treasury Regulation § 1.170A-13(c)

Appendix I: IRC § 170(f)(11)

Appendix J: IRS Notice 2006-96

Appendix K: Grantor and Grantee Considerations

Appendix L: Practical Tips