I 
116TH CONGRESS 
1ST SESSION H. R. 1727 
To amend the Internal Revenue Code of 1986 to allow a credit against 
income tax for qualified conservation contributions which include Na-
tional Scenic Trails. 
IN THE HOUSE OF REPRESENTATIVES 
MARCH 13, 2019 
Mr. CONNOLLY (for himself, Mr. TONKO, Mr. BLUMENAUER, Mr. PETERS, 
Mr. MCGOVERN, and Mr. CARTWRIGHT) introduced the following bill; 
which was referred to the Committee on Ways and Means, and in addi-
tion to the Committee on Natural Resources, for a period to be subse-
quently determined by the Speaker, in each case for consideration of such 
provisions as fall within the jurisdiction of the committee concerned 
A BILL 
To amend the Internal Revenue Code of 1986 to allow a 
credit against income tax for qualified conservation con-
tributions which include National Scenic Trails. 
Be it enacted by the Senate and House of Representa-
tives of the United States of America in Congress assembled, 
SECTION 1. SHORT TITLE. 
This Act may be cited as the ‘‘Complete America’s 
Great Trails Act’’. 
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SEC. 2. NATIONAL SCENIC TRAIL CONSERVATION CREDIT. 
(a) IN GENERAL.—Subpart B of part IV of sub-
chapter A of chapter 1 of the Internal Revenue Code of 
1986 is amended by adding at the end the following new 
section: 
‘‘SEC. 30E. NATIONAL SCENIC TRAIL CONSERVATION CRED-
IT. 
‘‘(a) ALLOWANCE OF CREDIT.—There shall be al-
lowed as a credit against the tax imposed by this chapter 
for the taxable year an amount equal to the fair market 
value of any National Scenic Trail conservation contribu-
tion of the taxpayer for the taxable year. 
‘‘(b) NATIONAL SCENIC TRAIL CONSERVATION CON-
TRIBUTION.—For purposes of this section— 
‘‘(1) IN GENERAL.—The term ‘National Scenic 
Trail conservation contribution’ means any qualified 
conservation contribution— 
‘‘(A) to the extent the qualified real prop-
erty interest with respect to such contribution 
includes a National Scenic Trail (or portion 
thereof) and its trail corridor, and 
‘‘(B) with respect to which the taxpayer 
makes an election under this section. 
‘‘(2) NATIONAL SCENIC TRAIL.—The term ‘Na-
tional Scenic Trail’ means any trail authorized and 
designated under section 5 of the National Trails 
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System Act (16 U.S.C. 1244), but only if such trail 
is at least 200 miles in length. 
‘‘(3) TRAIL
CORRIDOR.—The term ‘trail cor-
ridor’ means so much of the corridor of a trail as 
is— 
‘‘(A) not less than— 
‘‘(i) 150 feet wide on each side of 
such trail, or 
‘‘(ii) in the case of an interest in real 
property of the taxpayer which includes 
less than 150 feet on either side of such 
trail, the entire distance with respect to 
such interest on such side, and 
‘‘(B) not greater than 2,640 feet wide. 
‘‘(4) QUALIFIED
CONSERVATION
CONTRIBU-
TION; QUALIFIED REAL PROPERTY INTEREST.—The 
terms ‘qualified conservation contribution’ and 
‘qualified real property interest’ have the respective 
meanings given such terms by section 170(h), except 
that paragraph (2)(A) thereof shall be applied with-
out regard to any qualified mineral interest (as de-
fined in paragraph (6) thereof). 
‘‘(c) SPECIAL RULES.— 
‘‘(1) FAIR MARKET VALUE.—Fair market value 
of any National Scenic Trail conservation contribu-
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tion shall be determined under rules similar to the 
valuation rules under Treasury Regulations under 
section 170, except that in any case, to the extent 
practicable, fair market value shall be determined by 
reference to the highest and best use of the real 
property with respect to such contribution. 
‘‘(2) ELECTION
IRREVOCABLE.—An election 
under this section may not be revoked. 
‘‘(3) DENIAL OF DOUBLE BENEFIT.—No deduc-
tion shall be allowed under this chapter with respect 
to any qualified conservation contribution with re-
spect to which an election is made under this sec-
tion. 
‘‘(d) APPLICATION WITH OTHER CREDITS.— 
‘‘(1) BUSINESS CREDIT TREATED AS PART OF 
GENERAL BUSINESS CREDIT.—So much of the credit 
which would be allowed under subsection (a) for any 
taxable year (determined without regard to this sub-
section) that is attributable to property used in a 
trade or business or held for the production of in-
come shall be treated as a credit listed in section 
38(b) for such taxable year (and not allowed under 
subsection (a)). 
‘‘(2) PERSONAL CREDIT.—For purposes of this 
title, the credit allowed under subsection (a) for any 
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taxable year (determined after application of para-
graph (1)) shall be treated as a credit allowable 
under subpart A for such taxable year. 
‘‘(e) CARRYFORWARD OF UNUSED CREDIT.— 
‘‘(1) IN
GENERAL.—If the credit allowable 
under subsection (a) exceeds the limitation imposed 
by section 26(a) for any taxable year reduced by the 
sum of the credit allowable under subpart A (other 
than this section), such excess shall be carried to the 
succeeding taxable year and added to the credit al-
lowable under subsection (a) for such succeeding 
taxable year. 
‘‘(2) LIMITATION.—No credit may be carried 
forward under this subsection to any taxable year 
following the tenth taxable year after the taxable 
year in which the credit arose. For purposes of the 
preceding sentence, credits shall be treated as used 
on a first-in first-out basis.’’. 
(b) CONTINUED USE NOT INCONSISTENT WITH 
CONSERVATION PURPOSES.—A contribution of an interest 
in real property shall not fail to be treated as a National 
Scenic Trail conservation contribution (as defined in sec-
tion 30E(b) of the Internal Revenue Code of 1986) solely 
by reason of continued use of the real property, such as 
for recreational or agricultural use (including motor vehi-
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cle use related thereto), if, under the circumstances, such 
use does not impair significant conservation interests and 
is not inconsistent with the purposes of the National 
Trails System Act (16 U.S.C. 1241 et seq.). 
(c) STUDY REGARDING EFFICACY
OF NATIONAL 
SCENIC TRAIL CONSERVATION CREDIT.— 
(1) IN GENERAL.—The Secretary of the Inte-
rior shall, in consultation with the Secretary of the 
Treasury, study— 
(A) the efficacy of the National Scenic 
Trail conservation credit under section 30E of 
the Internal Revenue Code of 1986 in com-
pleting, extending, and increasing the number 
of National Scenic Trails (as defined in section 
30E(b) of such Code), and 
(B) the feasibility and estimated costs and 
benefits of— 
(i) making such credit refundable (in 
whole or in part), and 
(ii) allowing transfer of such credit. 
(2) REPORT.—Not later than 4 years after the 
date of the enactment of this Act, the Secretary of 
the Interior shall submit a report to Congress on the 
results of the study conducted under this subsection. 
(d) CONFORMING AMENDMENTS.— 
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