On December 23, 2016, the IRS announced disclosure requirements for participants in syndicated conservation easements and substantially similar transactions in Notice 2017-10. Section 3 of that notice required that participants with disclosure obligations under Treas. Reg. § 1.6011-4(e)(2)(i) file their disclosure by June 21, 2017. That deadline has been extended to October 2, 2017.
The May 1 deadline in the original notice remains for material advisors under Treas. Reg. § 301.6111-3(e). Finally, the new guidance clarifies that a donee under IRC § 170(c) is not a material advisor under IRC § 6111.
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