Conservation Easement Tax Issues: Recent IRS Enforcement, Structuring and Defending Easement Transactions

Ms. DeSantis-Then represents clients in government investigations, internal investigations, crisis management assistance and white-collar litigation. She has significant experience representing corporate and individual clients in parallel enforcement proceedings by multiple government entities, and in connection with congressional matters. Ms. DeSantis-Then represents clients in a wide variety of civil and criminal matters including False Claims Act and qui tam litigation, Foreign Corrupt Practices Act, health care fraud and abuse, Anti-Kickback Statute, agency noncompliance determinations, and other complex federal and state investigations. Her experience includes representing clients before the U.S. Department of Justice, Internal Revenue Service, Environmental Protection Agency, Securities and Exchange Commission, Federal Trade Commission, Department of Energy, Department of Health and Human Services, Indian Health Services, the U.S. Congress, Inspector General’s offices, as well as various attorneys general and state regulatory and enforcement bodies.

Ms. Fred's experience in the fields of tax, real estate, nonprofit governance, and alternative dispute resolution allows her to counsel her clients in all aspects of their work. Prior to beginning her legal career, she worked for several nonprofit environmental organizations, including serving as founder and Executive Director of the Humboldt Watershed Council.

Drawing on a dynamic background that spans tax law, accounting, finance, and securities, Mr. Steigleder provides his clients unique insight and a cohesive approach to minimize business and tax risks through tax planning and tax compliance, in assessing pre-controversy audit readiness, and in developing comprehensive audit, IRS Appeals, tax litigation, and settlement strategies. His undergraduate majors in accountancy and finance, his post-graduate Master of Business Administration (MBA) and Master of Law in Taxation (LLM), and his Securities Industry Essentials (SIE) and FINRA Series 7 and Series 63 certifications give him a rare fluency across the disciplines that converge in every serious tax dispute — tax law, financial valuation, business realities, and audit defense and litigation strategy. Mr. Steigleder regularly advises clients in preparing for, defending, and resolving tax controversies. He has significant experience managing tax audits, administrative appeals processes, structuring settlements, and litigating cases involving complex financial and tax-advantaged transactions, economic substance and substance-over-form issues, intercompany transactions and transfer pricing planning and defense, and other valuation issues.