IRS Continues Aggressive Stance on Charitable Contributions

Overview In a recent Tax Court decision handed down in a Memorandum opinion, the Internal Revenue Service (“IRS”) showed that it will continue to be aggressive in denying charitable deductions for transactions they might view as taking abuse of the charitable deduction available under Internal Revenue Code (“IRC”) §170. In Chrem v. Comm’r, TC Memo…
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Champions Retreat Denied Deduction for Golf Course Conservation Easement

The Tax Court recently struck down another conservation easement under Internal Revenue Code (“IRC”) IRC § 170(h). This case follows several other high-profile conservation easements that have been struck down recently. IRC § 170(h) and the related Treasury Regulations contain a myriad of technical requirements in order for an easement to qualify for the deduction,…
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Estate Planning for Nontaxable Estates

In the wake of the Tax Cuts and Jobs Act, P.L. 115-97 (Dec. 22, 2018), estate planning has seen a return to its genesis. At its core, estate planning is about making sure assets pass to the right people, at the right time, and in the right manner. For most estates, the estate tax tail…
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Interest Rates on the Rise: To Act or Wait?

The Internal Revenue Service recently released the Applicable Federal Rates (“AFR”) and the Section 7520 rate (“7520”) for August 2018. While the AFR remains low from a historical standpoint, as do interest rates in general, there has been a recent trend of rising interest rates. The short term AFR has increased from .56% for August 2016…
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