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Syndicated Conservation Easement Transactions For years I have been saying the the IRS is coming. The Internal Revenue Service announced today a significant increase in enforcement actions for syndicated conservation easement transactions, a priority compliance area for the agency. Coordinated examinations are being conducted across the IRS in the Small Business and Self-Employed Division, Large Business and International Division and Tax Exempt and Government Entities Division. Separately, investigations have been initiated by the IRS' Criminal Investigation division. These audits and investigations cover billions of dollars of potentially inflated deductions as well as hundreds of partnerships and thousands of investors. "We will not stop in our pursuit of everyone involved in the creation, marketing, promotion and wrongful acquisition of artificial, highly inflated deductions based on these aggressive transactions. Every available enforcement option wil

Syndicated Conservation Easements

For years at conventions I have warned of the IRS interest and pending audits. Now the IRS is going after easements and if you have used this tax strategy get help now. Most CPAS will not be able to help. If they sign a return with an abusive shelter on it they most report direct to the IRS, which means you get audited. syndicated conservation easements. Get help before it is too late. IRS has ramped up its enforcement efforts on syndicated conservation easements. On September 10, 2018, the IRS announced five new Large Business and International Division (“LB&I”) compliance campaigns, including a campaign focused on syndicated conservation easement transactions. This intensified scrutiny comes roughly 18 months after the IRS identified syndicated conservation easement transactions as listed transactions that require disclosure statements to the IRS by both investors and material advisors. This new effort will enhance IRS enforcement of those disclosure r
The IRS has announced in IR 2019-157 (9/16/2019) that it is mailing a time-limited settlement offer to certain taxpayers under audit who participated IRS IS COMING AND YOU NEED HELP NOW. PLEASE DO NOT WAIT. The IRS has announced in IR 2019-157 (9/16/2019) that it is mailing a time-limited settlement offer to certain taxpayers under audit who participated in abusive micro-captive insurance transactions. In recent days, the IRS started sending notices to up to 200 taxpayers. Transaction of Interest Broadly speaking, a micro-captive transaction is a transaction intended to reduce the aggregate taxable income of the taxpayer, related persons, or both, using contracts that the parties treat as insurance contracts and a related company that the parties treat as a captive insurance company. Each entity that the parties treat as an insured entity under the contracts claims deductions for insurance premiums. The related company that the parties treat as a capti

IRS uses tape recordings of undercover who forms 831(b) Captive

The Internal Revenue Service (IRS) had planned to use tape recordings of an undercover agent looking to form an 831(b) captive with Tribeca Strategic Pilot Series of Fortress Insurance v Commissioner , a case in which the taxpayer is accused of using a captive as a tax shelter, was scheduled for trial on June 3, 2019, although the case has now settled, with the taxpayers conceding beforehand. This case follows former clients of Artex seeking damages from it  in an Arizona-based lawsuit ,  Shivkov v Artex Risk Solutions , accusing the captive manager of conspiring to design, promote, sell, implement and manage illegal tax-advantaged captive insurance strategies using unlawful attempted 831(b) elections. An undercover agent recorded three conversations between 2006 and 2008 of Artex executives Karl Huish, Jim Tehero and Ken Kotch, as part of an investigation by the Criminal Investigation Division of the IRS relating to Tribeca and other affiliates. The re

Cryptocurrency transactions who potentially failed to report income

Cryptocurrency transactions who potentially failed to report income You need to get help now. The Internal Revenue Service  announced  today that it has begun mailing what it calls “educational letters” to taxpayers with The Internal Revenue Service  announced  today that it has begun mailing what it calls “educational letters” to taxpayers with cryptocurrency transactions who potentially failed to report income and pay the resulting tax from such transactions, or did not report their transactions properly. The IRS started sending these letters to taxpayers last week. By the end…who potentially failed to report income and pay the resulting tax from such transactions, or did not report their transactions properly. The IRS started sending these letters to taxpayers last week. By the end… Published on November 26, 2019

Expert Testimony in Cryptocurrency Matters

Cryptocurrency Explained Lance Wallach Digital and online forms of money handled through transactions constitute cryptocurrency, and these networked interactions lead to possible legal complications based on real world issues with the technical and financial realms. To understand these matters better, a courtroom may need the help of an expert witness to detail what cryptocurrency is and how it affects the plaintiff. In the digital world, computers and networking are becoming more important in the business and financial aspects of the globe, cryptocurrency has a purpose. The implications of online currency and payment for like services is not uncommon. However, by shifting income to strictly online aspects of money, it is possible for services and networked products to come to the forefront without real money interfering. Some may transfer cash into online gaming and other electronic pursuits, but cryptocurrency may remain digital payment for services and work without

Cryptocurrency Investors Are Being Audited

Cryptocurrency Investors Are Being Audited by IRS  Lance Wallach You will get a letter from the IRS if you are in a cryptocurrency. CPAS must report on you and that is part of the problem. You need to get help ASAP. Some easy steps can save you a lot of money and give you peace of mind. Lance Wallach, who speaks at legal and accounting conventions rarely meets an advisor that knows what to do. IRS 6707a talks about CPAs etc. must report on their clients or face a $100,000 fine, and that is a problem for their clients. More than 10,000 cryptocurrency investors face a decision as they open letters from the Internal Revenue Service informing them that they may owe taxes on their digital holdings. Should they quickly file amended tax returns correcting prior omissions or mistakes and hope that’s enough to avert an audit? Should big-time dodgers come forward and acknowledge their actions -- all while risking that the IRS might audit them or charge them with criminal tax