Recent developments across the three branches of government address the tax treatment of syndicated conservation easement transactions. The US Tax Court first held as invalid the notice designating the transactions as listed transactions. The Treasury and IRS then issued modified guidance in the form of proposed regulations, addressing the notice and comment deficiencies cited by the court. Finally, Congress enacted legislation separately addressing issues presented by these transactions.
Rob Galloway is a member of Baker McKenzie's North America Tax Practice Group where he focuses his practice on state and local tax matters. Prior to joining the Firm, Rob was an editor in the publishing industry in New York and also served two years in the United States Peace Corps in Mongolia.