IRS Wraps Up Dirty Dozen, Warns of Bogus Tax Avoidance Strategies (IR-2024-105)

The IRS has wrapped up the 2024 Dirty Dozen campaign, with a warning to taxpayers to beware of promoters selling bogus tax avoidance strategies. Promoters have been peddling elaborate bogus schemes to reduce taxes and make handsome profits. Fraudulent schemes can threatening taxpayers can include exploitative agreements related to syndicated conservation easements and micro-captive insurance arrangements. Some of these schemes even have an international aspect such as concealing money and digital-assets in foreign accounts. “Taxpayers should be wary of anything that seeks to completely eliminate a legitimate tax responsibility,” said IRS Commissioner Danny Werfel.

Generally, taxpayers can claim a charitable contribution deduction for the fair market value of a conservation easement transferred to a charity if the transfer meets the requirements under Code Sec. 170. Promoters in abusive agreements are offering easement transactions wherein the investor has the opportunity to claim charitable contribution deductions and corresponding tax savings that significantly exceed the amount the investor invested. The IRS has been committed to ensuring compliance with the conservation easement deduction law after the Congress amended the Code Sec. 170 to curb certain abusive transactions. Similarly, micro-captives involve schemes that lack many of the requisite attributes of a legitimate insurance. While many of these schemes are promoted and advertised online, the one thing in common to all are that they promise tax savings that are “too good to be true” and will likely cause legal harm to taxpayers who use them. The IRS warned taxpayers that the agency remains vigilant of these attempts to game the system. With abusive transactions and schemes being of high priority. The agency will challenge and impose penalties, where appropriate.

IR-2024-105