Conservation Easements: The Importance of Proper Planning and Compliance

The United States Tax Court recently decided yet another case[1] involving conservation easements and the corresponding charitable contribution deduction. Such cases have been prevalent lately, although recent cases have dealt more with syndicated conservation easements and the IRS’s failure to follow certain procedural rules.[2] In the subject case of this article, however, the Court, for…
Read More

Cross Refined Coal: A Partnership Recap

“If the government treats tax-advantaged transactions as shams unless they make economic sense on a pre-tax basis, then it takes away with the executive hand what it gives with the legislative.”[1] Despite these words issued by the Ninth Circuit in 1995, the Internal Revenue Service continues to challenge certain investments that Congress expressly encourages through…
Read More

Incomplete Non-Grantor Trusts: A Tax Planning Tool

In recent years, estate planners and tax practitioners have been utilizing incomplete non-grantor trusts, or ING trusts, with increased frequency. The most common use of ING trusts has been to minimize state income taxes, but an often-overlooked aspect of ING trusts is their effectiveness as a tax planning tool at the federal level. ING trusts…
Read More

Directions