IRS AUDITS CONSERVATION EASEMENTS AND CAPTIVE INSURANCE

According to an IRS Notice: The Treasury Department and the IRS have become aware that some promoters are syndicating conservation easement transactions that purport to give investors the opportunity to claim charitable contribution deductions in amounts that significantly exceed the amount invested. In such a syndicated conservation easement transaction, a promoter offers prospective investors in a partnership or other pass-through entity (“pass-through entity”) the possibility of a charitable contribution deduction for donation of a conservation easement. CAPTIVE INSURANCE AUDITS During the early 2010s, the IRS started investigating captives for abusive transactions. In 2016, the IRS published Notice 2016-66 in which the agency advised that micro-captive insurance transactions have the potential for tax avoidance or evasion. The IRS filed suit against companies paying premiums to captives and won three major lawsuits starting in 2017. Since micro-captive insurance companies were placed on the IRS’ “Dirty Dozen” list of tax scams in 2014 and identified as a transaction of interest in 2016, the IRS has continued to expand its enforcement efforts of what it views as abusive micro-captive insurance arrangements. Lance Wallach receives hundreds of phone calls to fight the IRS and help the consumer get all his money back from the promoter of these captive scams. As an expert witness Lance Wallach has never lost a case. 516 2368440. | Google him and your advisor, who do YOU trust? wallachinc@gmail.com