IRS Publication 550 — Investment Income and Expenses

have the number at that time, they must provide it within 60 calendar days from the date the number is mailed to them. For information on penalties for failure to disclose and failure to maintain lists, see sections 6707, 6707A, and 6708.

Requirement to maintain list. Material advisors must maintain a list of persons to whom they provide material aid, assistance, or advice on any reportable transaction. The list must be available for inspection by the IRS, and the information required to be included on the list must generally be kept for 7 years. See Regulations section 301.6112-1 for more information (including what information is required to be included on the list). Confidentiality privilege. The confidentiality privilege between you and a federally authorized tax practitioner does not apply to written communications made after October 21, 2004, regarding the promotion of your direct or indirect participation in any tax shelter. Appraisal requirement for donated property. If you claim a deduction of more than $5,000 for an item or group of similar items of donated property, you must generally get a qualified appraisal. See section 170 and Form 8283 for more information. If you claim a deduction of more than $500,000 for the donated property, you must generally attach the qualified appraisal to your return. See Pub. 561 for information about appraisals. If you file electronically, see Form 8453, U.S. Individual Income Tax Transmittal for an IRS e-file Return, for the latest information. Conservation easements. The IRS issued final Regulations section 1. 6011-9 to identify certain syndicated conservation easement transactions and substantially similar transactions as listed transactions. These transactions require additional disclosures by advisors and certain participants as a reportable transaction. The definition of the term “conservation easement” is modified to include a restriction (granted in perpetuity) on the use that may be made of the real property, within the meaning of section 170(h)(2)(C), exclusively for conservation purposes, within the meaning of section 170(h)(1)(C) and (h)(4). The preservation of a certified historic structure is included in the definition of real property for purposes of identifying a transaction as a listed transaction. See Regulations section 1. 6011-9, effective October 8, 2024, for details and examples.

Limits on deductions for donations of conservation contributions by pass -through entities. For contributions made after December 29, 2022, a deduction for a donation of a qualified conservation contribution by a partnership or S corporation is limited to 2.5 times the sum of each partner’s relevant basis. Any contribution in excess of that amount is generally disallowed and not treated as a qualified conservation contribution. See section 170(h)(7) for exceptions. Additionally, under section 6664(c)(2) for contributions made after December 29, 2022, there is no reasonable cause exception to the accuracy-related penalty for disallowed syndicated conservation easement deductions. For additional information regarding penalties, see Penalties, later.