I 
118TH CONGRESS 
2D SESSION H. R. 10521 
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 
DECEMBER 19, 2024 
Mr. CONNOLLY introduced the following bill; which was referred to the Com-
mittee on Ways and Means, and in addition to the Committee on Natural 
Resources, for a period to be subsequently determined by the Speaker, 
in each case for consideration of such provisions as fall within the juris-
diction 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’’. 
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 
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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 
System Act (16 U.S.C. 1244). 
‘‘(3) TRAIL CORRIDOR.— 
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‘‘(A) IN GENERAL.—The term ‘trail cor-
ridor’ means so much of the corridor of a trail 
as is— 
‘‘(i) subject to subparagraph (B), not 
less than 50 feet wide on each side of such 
trail, and 
‘‘(ii) not greater than 2,640 feet wide. 
‘‘(B) EXCEPTIONS.— 
‘‘(i) LESS THAN 50 FEET WIDE ON A 
SIDE OF THE TRAIL.—In the case of an in-
terest in real property of the taxpayer 
which includes less than 50 feet on either 
side of the trail, the trail corridor shall in-
clude the entire distance with respect to 
such interest on such side. 
‘‘(ii) BUILDING
AND
STRUCTURES 
NEAR THE TRAIL.—In the case of an inter-
est in real property of the taxpayer which 
includes a residence or structure owned by 
the taxpayer which is located less than 50 
feet from the trail, the trail corridor for 
the side of the trail on which the residence 
or structure is located shall include such 
distance from the trail as is determined 
appropriate by the taxpayer. 
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‘‘(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-
tion shall be determined in the same manner as 
qualified conservation contributions under section 
170, except that in any case, to the extent prac-
ticable, fair market value shall be determined by ref-
erence to the highest and best use of the real prop-
erty 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.— 
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‘‘(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 
taxable year (determined after the application of 
paragraph (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— 
‘‘(A) the limitation imposed by section 
26(a) for any taxable year, reduced by 
‘‘(B) the sum of the credits allowable 
under subpart A (other than this section) for 
the taxable year, 
such excess shall be carried to the succeeding tax-
able year and added to the credit allowable under 
subsection (a) for such succeeding taxable year. 
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‘‘(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-
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-
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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 AMENDMENT.—The table of sec-
tions for subpart B of part IV of subchapter A of chapter 
1 of such Code is amended by adding at the end the fol-
lowing new item: 
‘‘30E. National Scenic Trail conservation credit.’’. 
(e) EFFECTIVE DATE.—The amendments made by 
this section shall apply to contributions made after the 
date of the enactment of this Act. 
Æ 
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