via IRS looking to crack down on land donation abuse
Conservation land easements may be the target of IRS reform before year’s end, according to a member of the agency’s chief counsel.
The main problem: Tax advisers who help landowners sell the tax deductions they get for land donations to other taxpayers. Such moves, called syndications, are typically done because a landowner doesn't have enough income to make full use of a sizable tax deduction.
Tax deductions cannot be legally sold to other taxpayers, so a structure such as a limited liability company is created, the land becomes an asset of that company, and shares are sold to others. When land is donated, each shareholder can apply any tax deductions to their personal taxes.
If you are involved in land conservation or have ever considered purchasing these syndications, this is an excellent read on the new pressure that is forthcoming from the IRS.