“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 partnerships an election to resolve open tax controversies over deductions claimed for qualified conservation contributions made in taxable years ending on or before December 31, 2024. The election must be filed within the 180-day period beginning on the date of enactment and applies to matters where the assessment period remains open or the IRS has issued a notice of review, examination, or proposed adjustment.
This section revises the eligibility standard for buildings in historic districts to qualify for charitable deductions of qualified conservation contributions under section 170 and the rehabilitation tax credit under section 47 by requiring them to be contributing buildings rather than certified as historically significant to the district. It defines a contributing building as one identified in the National Register nomination, any amendment, or official district documentation on file with or approved by the Secretary of the Interior, or certified by the Secretary as contributing to the district's historic significance. The section 170 changes apply to contributions in open taxable years or pending proceedings as of enactment, while the section 47 changes apply to taxable years beginning after enactment.