Conservation Easements and Captive Insurance, get audited

The IRS stated that the agency continued to step up its pursuit of those who promote and make use of abusive tax shelters, including syndicated conservation easements, where it saw successful Tax Court litigation and the completion of the first settlement initiative, the report noted. [IR-2021-03 (Jan. 5, 2021)] Two Atlanta tax professionals pleaded guilty to conspiracy charges in what the U.S. Justice Department touted as its first criminal case involving tax-advantaged land deals known as syndicated conservation easements. Captive insurance: The Treasury Department and the IRS believe this transaction (“micro-captive transaction”) has a potential for tax avoidance or evasion. See IR–2016–25 (discussing characteristics of an abusive micro-captive insurance structure). However, the Treasury Department and the IRS lack sufficient information to identify which § 831(b) arrangements should be identified specifically as a tax avoidance transaction and may lack sufficient information to define the characteristics that distinguish the tax avoidance transactions from other § 831(b) related-party transactions. This notice identifies the transaction described in section 2.01 of this notice and substantially similar transactions as transactions of interest for purposes of § 1.6011–4(b)(6) of the Income Tax Regulations and §§ 6111 and 6112 of the Code. This notice also alerts persons involved in such transactions to certain responsibilities and penalties that may arise from their involvement with these transactions. Lance Wallach has received hundreds of calls to help people in these tax shelters fight the IRS and sue the salesmen of these tax scams. 516 2368440 As an expert witness Lance Wallach has never lost a case. Google him and your advisor, who do YOU trust?