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II
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 Representa-
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tives of the United States of America in Congress assembled,
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SECTION 1. SHORT TITLE.
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This Act may be cited as the ‘‘Charitable Conserva-
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tion Easement Program Integrity Act of 2019’’.
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•S 170 IS
SEC. 2. LIMITATION ON PARTNER’S DEDUCTION FOR
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QUALIFIED CONSERVATION CONTRIBUTIONS
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MADE BY PARTNERSHIP.
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(a) IN GENERAL.—Section 170(h) of the Internal
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Revenue Code of 1986 is amended by adding at the end
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the following new paragraph:
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‘‘(7) LIMITATION
ON
PARTNERSHIP
ALLOCA-
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TION OF CONTRIBUTIONS.—
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‘‘(A) IN
GENERAL.—In the case of any
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qualified conservation contributions of any part-
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nership (whether directly or as a distributive
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share of such contributions of another partner-
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ship), no amount of such contributions may be
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taken into account under this section by any
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partner of such partnership as a distributive
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share of such contributions if the aggregate
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amount so taken into account by such partner
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for the taxable year would (but for this para-
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graph) exceed 2.5 times such partner’s adjusted
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basis in such partnership (determined as of the
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close of such taxable year and without regard to
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such contributions). The preceding sentence
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shall apply only with respect to the first 3 tax-
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able years of such partner which end after the
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date on which such partner first became a part-
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ner in the partnership.
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•S 170 IS
‘‘(B) EXCEPTION FOR FAMILY PARTNER-
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SHIPS.—Subparagraph (A) shall not apply with
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respect to any partnership if substantially all of
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the partnership interests in such partnership
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are held by individuals who are related within
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the meaning of section 152(d)(2).
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‘‘(C) REGULATIONS.—The Secretary shall
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prescribe such regulations or other guidance as
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may be necessary to carry out, and prevent the
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avoidance of, the purposes of this paragraph.’’.
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(b) EFFECTIVE DATE.—This section shall apply to
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contributions made in taxable years ending after Decem-
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ber 23, 2016. No inference is intended as the appropriate
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treatment of contributions made in taxable years ending
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on or before such date or as to any activity not described
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in section 170(h)(7) of the Internal Revenue Code of
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1986, as added by this section.
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Æ
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