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ARTICLE · 30 OCTOBER 2024

IRS Issues Final Regulations For Syndicated Conservation Easement Transactions

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On Oct. 8, 2024, the Treasury Department and Internal Revenue Service issued final regulations identifying syndicated conservation easement transactions as listed transactions for purposes of I.R.C. § 6011.

United StatesTax
Barbara Kaplan
Barbara Kaplan
Courtney A. Hopley
Courtney A. Hopley
Samuel Weinstein Astorga
Samuel Weinstein Astorga

On Oct. 8, 2024, the Treasury Department and Internal Revenue Service issued final regulations identifying syndicated conservation easement transactions as listed transactions for purposes of I.R.C. § 6011. The regulations are a response to a series of taxpayer victories involving the Administrative Procedure Act (APA)'s application to the IRS's identification of listed transactions, including the syndicated conservation easement transaction listing notice (Notice 2017-10). For a more detailed explanation of taxpayer victories, see our December 2022 GT Alert.

Treasury and IRS first issued proposed regulations on Dec. 8, 2022, and, a few weeks later, Congress signed the SECURE 2.0 Act of 2022, which added section 170(h)(7) to the Internal Revenue Code. Section 170(h)(7) limits qualified conservation contributions by partnerships and S corporations. Commenting on the SECURE 2.0 Act, Treasury and IRS stated that they took a "more surgical approach" to defining

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