The IRS today released an advance version of Notice 2017-29 that extends the due date for participants filing disclosures under Notice 2017-10 (relating to syndicated conservation easement transactions) and clarifies that for purposes of Notice 2017-10, a donee described in section 170(c) is not a material advisor.
Notice 2017-29 [PDF 12 KB] extends the due date for participants filing disclosures from June 21, 2017, until October 2, 2017.
The due date for disclosure by material advisors and participants who have disclosure obligations (regarding returns filed after December 23, 2016) with respect to the transaction described in Notice 2017-10 is unchanged and remains May 1, 2017.
Notice 2017-10 was released in December 2016 to identify certain "syndicated conservation easement transactions" as tax avoidance transactions. The 2016 notice identifies these transactions, and substantially similar transactions, as "listed transactions" for purposes of Reg. section 1.6011-4(b)(2) and sections 6111 and 6112. Read TaxNewsFlash
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