subsection (b)(2) under which the qualified
forestland qualified under subsection (a).
‘‘(4) CERTAIN RULES MADE APPLICABLE.—The
rules of the last sentence of section 1033(a)(2)(A)
shall apply for purposes of paragraph (3)(B)(ii).
‘‘(g) EXCHANGES OF QUALIFIED FORESTLAND.—
‘‘(1) 
TREATMENT
OF
PROPERTY
EX-
CHANGED.—
‘‘(A) EXCHANGES SOLELY FOR QUALIFIED
EXCHANGE PROPERTY.—If an interest in quali-
fied forestland is exchanged solely for an inter-
est in qualified exchange property in a trans-
action which qualifies under section 1031, no
tax shall be imposed by subsection (c) by reason
of such exchange.
‘‘(B) EXCHANGES
WHERE
OTHER
PROP-
ERTY
RECEIVED.—If an interest in qualified
forestland is exchanged for an interest in quali-
fied exchange property and other property in a
transaction which qualifies under section 1031,
the amount of the tax imposed by subsection (c)
by reason of such exchange shall be the amount
of tax which (but for this subparagraph) would
have been imposed on such exchange under sub-
section (c)(1), reduced by an amount which—
‘‘(i) bears the same ratio to such tax,
as
‘‘(ii) the value of the qualified ex-
change property bears to the value of the
qualified forestland exchanged.
For purposes of clause (ii), value shall be deter-
mined according to subsection (e)(6).
‘‘(2) TREATMENT
OF
QUALIFIED
EXCHANGE
PROPERTY.—For purposes of subsection (c)—
‘‘(A) any interest in qualified exchange
property shall be treated in the same manner as
if it were a portion of the interest in qualified
forestland which was exchanged; and
‘‘(B) any tax imposed by subsection (c) by
reason of the exchange shall be treated as a tax
imposed on a partial disposition.
‘‘(3) QUALIFIED
EXCHANGE
PROPERTY.—For
purposes of this subsection, the term ‘qualified ex-
change property’ means real property which is to be
used for a qualified forest use set forth in subsection
(b)(2) under which the real property exchanged
therefor originally qualified under subsection (a).’’
(b) CONFORMING AMENDMENTS.—
(1) Section 1014(a)(3) is amended by inserting
‘‘or 2032B’’ after ‘‘2032A’’.
(2) Section 1016(c) is amended—
(A) by inserting ‘‘or 2032B(c)(1)’’ after
‘‘2032A(c)(1)’’ in paragraphs (1), (3), (4), and
(5)(B),
(B) by inserting ‘‘or qualified devisee’’
after ‘‘qualified heir’’ in paragraph (1),
(C) by inserting ‘‘or 2032B(f)(3)(B)’’ after
‘‘2032A(h)(3)(B)’’ in paragraph (4), and
(D) by inserting ‘‘or 2032B(g)(3)’’ after
‘‘2032A(i)(3)’’ in paragraph (4).
(3) Section 1040 is amended—
(A) by inserting ‘‘or qualified devisee
(within the meaning of section 2032B(e)(1))’’
before ‘‘any property’’ in subsection (a), and
(B) 
by 
inserting 
‘‘or 
2032B’’ 
after
‘‘2032A’’ in subsections (a) and (b).
(4) Section 1223(12)(C) is amended by insert-
ing ‘‘or qualified devisee (within the meaning of sec-
tion 2032B(e)(1))’’ before ‘‘with respect’’.
(5) Section 2013 is amended—
(A) 
by 
inserting 
‘‘or 
2032B’’ 
after
‘‘2032A’’ each place it appears in subsection (f)
and the heading thereof, and
(B) by inserting ‘‘or 2032B(c)’’ after
‘‘2032A(c)’’ both places it appears in subsection
(f).
(6) Section 2035(d)(3)(B) is amended by in-
serting ‘‘or section 2032B (relating to special valu-
ation of certain forestland)’’ after ‘‘real property)’’.
(7) Section 2056A(b)(10)(A) is amended by in-
serting ‘‘2032B,’’ after ‘‘2032A,’’.
(8) Section 2624(b) is amended by striking
‘‘sections 2032 and 2032A’’ and inserting ‘‘sections
2032, 2032A, and 2032B’’.
(9) Section 2663(1) is amended by striking
‘‘section 
2032A(c)’’ 
and 
inserting 
‘‘sections
2032A(c) and 2032B(c)’’.
(10) Section 6324B is amended—
(A) by striking subsection (a) and insert-
ing the following new subsection:
‘‘(a) GENERAL RULES.—
‘‘(1) SECTION 2032A.—In the case of any inter-
est in qualified real property (within the meaning of
section 2032A(b)), an amount equal to the adjusted
tax difference attributable to such interest (within
the meaning of section 2032B(c)(2)(A)) shall be a
lien in favor of the United States on property in
which such interest exists.