Final Regulations on Syndicated Conservation Easement Transactions as Listed Transactions

Summary

This practice note discusses final regulations that were issued by the Internal Revenue Service and the Department of the Treasury under I.R.C. Section 6011 to identify certain syndicated conservation easement transactions and substantially similar transactions as listed transactions. Listed transactions are transactions that may have the potential for tax avoidance or evasion. The final regulations affect material advisors and other participants in listed transactions who are required to file disclosures with the IRS and are subject to penalties for failure to disclose.