Kostelanetz partner Christopher Ferguson will speak at the IRS Representation Conference on November 8, 2024. He is a panelist for the session “Enforcement Trends: What’s Hot and What’s Not” that will be held from 10:15 AM to 11:05 AM Eastern. The panel will cover a variety of tax enforcement topics,
Bryan C. Skarlatos was quoted in a recent Wall Street Journal article titled “A Tax-Shelter Crackdown Uncovers a Dentist’s ‘Smile High Trust,’” which examines IRS enforcement efforts against tax shelter promotions involving alleged tax-reducing trusts that are targeted to “wealthy individuals, business owners and professionals like doctors and lawyers.” The
Yesterday, the U.S. Treasury Department issued final regulations (TD 10007, RIN 1545-BQ39) that identify certain syndicated conservation easement transactions (SCE) and substantially similar transactions as “listed transactions.” These SCE transactions must be reported on Form 8886, Reportable Transaction Disclosure Statement. In addition, material advisers to any reportable transaction are required
