The Tax Court recently issued a full T.C. opinion which will impact a tremendous number of conservation easement donations. In Pine Mountain Preserve, LLLP v. Commissioner, 151 T.C. 4 (2018) the Tax Court found a reservation of rights to construct certain improvement within a floating building envelope resulted in a conservation easement failing to constitute a qualified real property interest granted in perpetuity. As a result, no deduction was allowed for the grant of the conservation easement.
Taxpayers have commonly reserved the right to construct improvements within a ...
On January 18, 2019, Treasury and the IRS issued final regulations for the new Section 199A 20% profit deduction for pass-thru businesses adopted under the 2017 Tax Cuts and Jobs Acts. The new regulations are eagerly anticipated because filing season for the first year of the new tax law, 2018 generally, is now upon us. The final regulations were issued after public comments were received in response to proposed Section 199A regulations issued last August. The IRS, in IR-2019-04 (January 18, 2019), also released a new set of additional proposed resolutions under Section 199A ...