Title: Charitable Conservation Easement Program Integrity Act of 2017
Policy area: Taxation

Summary:
Charitable Conservation Easement Program Integrity Act of 2017
This bill amends the Internal Revenue Code to limit the aggregate amount of a partner's annual tax deductions for qualified conservation contributions of a partnership to 2.5 times the partner's adjusted basis in the partnership. (Under current law, a "qualified conservation contribution" is the contribution of a qualified real property interest to a qualified organization exclusively for conservation purposes.)
The limitation applies for the first five years after the individual becomes a partner in the partnership. It does not apply to certain family partnerships.

[Congressional Bills 115th Congress]
[From the U.S. Government Publishing Office]
[H.R. 4459 Introduced in House (IH)]

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115th CONGRESS
  1st Session
                                H. R. 4459

   To amend the Internal Revenue Code of 1986 to limit the amount of 
             certain qualified conservation contributions.


_______________________________________________________________________


                    IN THE HOUSE OF REPRESENTATIVES

                           November 28, 2017

Mr. Thompson of California (for himself and Mr. Kelly of Pennsylvania) 
 introduced the following bill; which was referred to the Committee on 
                             Ways and Means

_______________________________________________________________________

                                 A BILL


 
   To amend the Internal Revenue Code of 1986 to limit the amount of 
             certain qualified conservation contributions.

    Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

    This Act may be cited as the ``Charitable Conservation Easement 
Program Integrity Act of 2017''.

SEC. 2. LIMITATION ON PARTNER'S DEDUCTION FOR QUALIFIED CONSERVATION 
              CONTRIBUTIONS MADE BY PARTNERSHIP.

    (a) In General.--Section 170(h) of the Internal Revenue Code of 
1986 is amended by adding at the end the following new paragraph:
            ``(7) Limitation on partnership allocation of 
        contributions.--
                    ``(A) In general.--In the case of any qualified 
                conservation contributions of any partnership (whether 
                directly or as a distributive share of such 
                contributions of another partnership), no amount of 
                such contributions may be taken into account under this 
                section by any partner of such partnership as a 
                distributive share of such contributions if the 
                aggregate amount so taken into account by such partner 
                for the taxable year would (but for this paragraph) 
                exceed 2.5 times such partner's adjusted basis in such 
                partnership (determined as of the close of such taxable 
                year and without regard to such contributions). The 
                preceding sentence shall only apply with respect to the 
                first 5 taxable years of such partner which end after 
                the date on which such partner first became a partner 
                in the partnership.
                    ``(B) Exception for family partnerships.--
                Subparagraph (A) shall not apply with respect to any 
                partnership if substantially all of the partnership 
                interests in such partnership are held by individuals 
                who are related within the meaning of section 
                152(d)(2).
                    ``(C) Regulations.--The Secretary shall prescribe 
                such regulation or other guidance as may be necessary 
                to carry out, and prevent the avoidance of, the 
                purposes of this paragraph.''.
    (b) Effective Date.--This section shall apply to contributions made 
after December 23, 2016. No inference is intended as the appropriate 
treatment of contributions made on or before such date or as to any 
activity not described in section 170(b)(7) of the Internal Revenue 
Code of 1986, as added by this section.
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