,,ii  #aafth ,,congress  #b;d ,session  
,s4 #ejai  ,,in ,,the ,,senate ,,of     
,,the ,,united ,,states  ,december #ae1 
#bjbj,mr4 ,daines 7for himself1 ,ms4    
,stabenow1 ,mr4 ,grassley1 and ,mr4     
,wyden7 introduced the following bill2  
which was read twice and referred to the
 ,committee on ,finance  ,a ,,bill  ,to 
amend the ,internal ,revenue ,code of   
#aihf to limit the charitable deduction 
for certain qualified conservation      
contributions4  #a4 ,short title ,this  
,act may be cited as the ,charitable    
,conservation ,easement ,program        
,integrity ,act of #bjbj4  #b4          
,limitation on deduction for qualified  
conservation contributions made by      
pass-through entity  7a7 ,in general    
,section #agj7;h7 of the ,internal      
,revenue ,code of #aihf is amended by   
adding at the end the following new     
paragraph3  7#g7 ,limitation on         
deduction for qualified conservation    
contributions made by pass-through      
entity  7,a7 ,in general ,in the case of

 any qualified conservation contribution
 of any partnership 7whether directly or
 as a distributive share of such        
contribution of another partnership71 no
 amount of such contribution may be     
taken into account under this section by
 any partner of such partnership as a   
distributive share of such contribution 
if the aggregate amount so taken into   
account by such partner for the taxable 
year would 7but for this paragraph7     
exceed #b4e times the portion of the    
adjusted basis of such partner's        
interest in such partnership 7determined
 immediately before such contribution   
and without regard to section #geb7     
which is allocable 7under rules similar 
to the rules of section #gee7 to the    
qualified real property interest with   
respect to which such contribution is   
made4  7,b7 ,exception for contributions
 outside #c-year holding period         
,subparagraph 7,a7 shall not apply to a 
partner's distributive share of a       
qualified conservation contribution if  

such contribution is made-- 7i7 at least
 #c years after the date the partnership
 acquired the entirety of the qualified 
real property interest with respect to  
which such contribution is made1  7ii7  
at least #c years after the date the    
partner acquired the partner's entire   
interest in the partnership with respect
 to which such distributive share is    
determined1 and  7iii7 if the interest  
in the partnership making such          
contribution is held through #a or more 
partnerships1 at least #c years after   
each such partnership acquired the      
entirety of the interest in any such    
partnership with respect to which such  
distributive share is determined4  7,c7 
,exception for family partnerships      
,subparagraph 7,a7 shall not apply with 
respect to any qualified conservation   
contribution made by any partnership if 
substantially all of the partnership    
interests in such partnership are held1 
directly or indirectly1 by individuals  
who are members of the same family      

7within the meaning of section          
#ebi7;e77#b774  7,d7 ,application to    
other pass-through entities ,except as  
may be otherwise provided by the        
,secretary1 the rules of this paragraph 
shall apply to ,s corporations and other
 pass-through entities in the same      
manner as such rules apply to           
partnerships4  7,e7 ,regulations ,the   
,secretary shall prescribe such         
regulations or other guidance as may be 
necessary to carry out1 and prevent the 
avoidance of1 the purposes of this      
paragraph1 including1 in the case of    
tiered partnerships1 such reporting to  
the ,secretary and among such           
partnerships as the ,secretary          
determines appropriate4  4  7b7         
,effective date  7#a7 ,in general       
,except as provided in paragraph 7#b71  
the amendment made by this section shall
 apply to contributions made in taxable 
years ending after ,december #bc1 #bjaf4
  7#b7 ,certified historic structures   
,in the case of contributions the       

conservation purpose 7as defined in     
section #agj7;h77#d7 of the ,internal   
,revenue ,code of #aihf7 of which is the
 preservation of a certified historic   
structure 7as defined in section        
#agj7;h77#d77;,c7 of such ,code71 the   
amendment made by this section shall    
apply to contributions made in taxable  
years beginning after ,december #ca1    
#bjah4  7#c7 ,no inference ,no inference
 is intended as to the appropriate      
treatment of contributions made in      
taxable years ending on or before the   
date specified in paragraph 7#a7 or     
7#b71 whichever is applicable1 or as to 
any activity not described in section   
#agj7;h77#g7 of the ,internal ,revenue  
,code of #aihf1 as added by this        
section4