“To provide an election to resolve certain open partnership controversies involving donations of conservation easements.”
No CRS summary available for this bill.
This section provides definitions for an election allowing partnerships to resolve open tax controversies over conservation easement donations. Eligible contributions include qualified conservation contributions under section 170(h) claimed on partnership returns for taxable years ending on or before December 31, 2025, with the claimed deduction measured by amounts allocated to ultimate taxpayer partners. Open matters cover cases where the assessment period under chapter 1 has not expired or where the IRS has issued written notices of review or examination. The 360-day election period begins on the date of enactment, and common marketing groups encompass all partnerships sharing the same principal organizer or manager.
This section revises the eligibility standard for qualified conservation contributions of buildings in registered historic districts under section 170 and for certified historic structures under the rehabilitation credit in section 47. It replaces the prior certification requirement with a "contributing building" standard, defined as any building identified as contributing in the National Register nomination, district documentation, or certified by the Secretary of the Interior as contributing to the district. The section 170 changes apply to contributions in any open tax year or pending proceeding, while the section 47 changes apply to taxable years beginning after enactment.