Title: Charitable Conservation Easement Program Integrity Act of 2019
Policy area: Taxation

Summary:
Charitable Conservation Easement Program Integrity Act of 2019
This bill limits 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 three taxable years after the individual becomes a partner in the partnership. It does not apply to certain family partnerships.

[Congressional Bills 116th Congress]
[From the U.S. Government Publishing Office]
[S. 170 Introduced in Senate (IS)]

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116th CONGRESS
  1st Session
                                 S. 170

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


_______________________________________________________________________


                   IN THE SENATE OF THE UNITED STATES

                            January 16, 2019

  Mr. Daines (for himself and Ms. Stabenow) introduced the following 
  bill; which was read twice and referred to the Committee on Finance

_______________________________________________________________________

                                 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 2019''.

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 apply only with respect to the 
                first 3 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 regulations 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 
in taxable years ending after December 23, 2016. No inference is 
intended as the appropriate treatment of contributions made in taxable 
years ending on or before such date or as to any activity not described 
in section 170(h)(7) of the Internal Revenue Code of 1986, as added by 
this section.
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