Syndicated Conservation Easement Transactions as Listed Transactions

Urban Farm DB summary

On 8 October 2024 the IRS and Treasury issued final regulations (TD 10007, RIN 1545-BQ39) identifying certain syndicated conservation easement transactions and substantially similar transactions as listed transactions, a type of reportable transaction. Material advisors and certain participants must file disclosures with the IRS and face penalties for failing to do so. Public comments on the proposed rule extensively discussed the so-called '2.5 times rule' — a multiple-of-investment threshold used to flag transactions.

Only numbers and their conditions are stored, as structured data — never the source's own sentences. Metric and condition names stay in English, as coded.

• 2024 10 08発効

  regulation effective date(syndicated conservation easement)

  Policy

  region

  United States

  instrument

  TD 10007

• 2.5 ratio

  deduction to investment multiple threshold(syndicated conservation easement)

  Policy

  region

  United States

  instrument

  section 170(h)(7)

  note

  「2.5倍ルール」としてコメントで議論

Direction of conclusions

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• Policy and governanceSupportsWith caveats