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Abstract: 

Even though charitable contributions of conservation easements have been part of the Internal Revenue Code for decades, nonetheless, the increasing focus on the “greening” of America has served to direct attention to this complex and highly technical area of income and excise taxation. Conservation easements, similar to other easements, may be the subject of a sale or exchange. However, in an attempt to encourage a greater legacy of protected environments for future generations, legislation has increased the attractiveness of contributing conservation easements. The Internal Revenue Service (hereinafter referred to as IRS or Service) has clarified its position on the technicalities surrounding qualified conservation easements (i.e., QCE) through the issuance of several recent Letter Rulings. In spite of a paucity of court cases, judicial concerns and reasonings provided by the resolved cases of easements for income tax purposes reveal planning insights to avoid potential pitfalls.

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Affiliations:  1: Louisiana Tech University School of Professional Accountancy; 2: Louisiana Tech University School of Professional Accountancy.