,,ii #aagth ,,congress #ast ,session ,s4 #bbef ,,in ,,the ,,senate ,,of ,,the ,,united ,,states ,june #bd1 #bjba,mr4 ,daines 7for himself1 ,ms4 ,stabenow1 ,mr4 ,wyden1 and ,mr4 ,grassley7 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 #bjba4 #b4 ,limitation on deduction for qualified conservation contributions made by pass-through entities 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 entities 7,a7 ,in general ,a contribution by a partnership 7whether directly or as a distributive share of a contribution of another partnership7 shall not be treated as a qualified conservation contribution for purposes of this section if the amount of such contribution exceeds #b4e times the sum of each partner's relevant basis in such partnership4 7,b7 ,relevant basis ,for purposes of this paragraph-- 7i7 ,in general ,the term relevant basis means1 with respect to any partner1 the portion of such partner's modified basis in the partnership which is allocable 7under rules similar to the rules of section #gee7 to the portion of the real property with respect to which the contribution described in subparagraph 7,a7 is made4 7ii7 ,modified basis ,the term modified basis means1 with respect to any partner1 such partner's adjusted basis in the partnership as determined-- 7,i7 immediately before the contribution described in subparagraph 7,a71 7,,ii7 without regard to section #geb1 and 7,,iii7 by the partnership after taking into account the adjustments described in subclauses 7,i7 and 7,,ii7 and such other adjustments as the ,secretary may provide4 7,c7 ,exception for contributions outside #c-year holding period ,subparagraph 7,a7 shall not apply to any contribution which is made at least #c years after the latest of-- 7i7 the last date on which the partnership that made such contribution acquired any portion of the real property with respect to which such contribution is made1 7ii7 the last date on which any partner in the partnership that made such contribution acquired any interest in such partnership1 and 7iii7 if the interest in the partnership that made such contribution is held through one or more partnerships-- 7,i7 the last date on which any such partnership acquired any interest in any other such partnership1 and 7,,ii7 the last date on which any partner in any such partnership acquired any interest in such partnership4 7,d7 ,exception for family partnerships 7i7 ,in general ,subparagraph 7,a7 shall not apply with respect to any contribution made by any partnership if substantially all of the partnership interests in such partnership are held1 directly or indirectly1 by an individual and members of the family of such individual4 7ii7 ,members of the family ,for purposes of this subparagraph1 the term members of the family means1 with respect to any individual-- 7,i7 the spouse of such individual1 and 7,,ii7 any individual who bears a relationship to such individual which is described in subparagraphs 7,a7 through 7,g7 of section #aeb7;d77#b74 7,e7 ,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,f7 ,regulations ,the ,secretary shall prescribe such regulations or other guidance as may be necessary or appropriate to carry out the purposes of this paragraph1 including regulations or other guidance-- 7i7 to require reporting1 including reporting related to tiered partnerships and the modified basis of partners1 and 7ii7 to prevent the avoidance of the purposes of this paragraph4 4 7b7 ,application of accuracy-,related penalties 7#a7 ,in general ,section #fffb7;b7 of the ,internal ,revenue ,code of #aihf is amended by inserting after paragraph 7#i7 the following new paragraph3 7#aj7 ,any disallowance of a deduction by reason of section #agj7;h77#g74 4 7#b7 ,treatment as gross valuation misstatement ,section #fffb7;h77#b7 of such ,code is amended by striking and at the end of subparagraph 7,b71 by striking the period at the end of subparagraph 7,c7 and inserting 1 and1 and by adding at the end the following new subparagraph3 7,d7 any disallowance of a deduction described in subsection 7b77#aj74 4 7#c7 ,no reasonable cause exception ,section #fffd7;c77#b7 of such ,code is amended by inserting or to any disallowance of a deduction described in section #fffb7;b77#aj7 before the period at the end4 7#d7 ,approval of assessment not required ,section #fgea7;b77#b77;,a7 of such ,code is amended by striking subsection 7b77#i7 and inserting paragraph 7#i7 or 7#aj7 of subsection 7b74 7c7 ,application of statute of limitations on assessment and collection 7#a7 ,extension for certain adjustments made under prior law ,in the case of any disallowance of a deduction by reason of section #agj7;h77#g7 of the ,internal ,revenue ,code of #aihf 7as added by this section7 or any penalty imposed under section #fffb of such ,code with respect to such disallowance1 section #fbbi7;d77#b7 of such ,code 7as in effect before its repeal7 shall be applied by substituting #b years for #a year4 7#b7 ,extension for listed transactions ,any contribution described in section #agj7;h77#g77;,a7 of the ,internal ,revenue ,code of #aihf 7as added by this section7 shall be treated for purpose of sections #feja7;c77#aj7 and #fbce7;c77#f7 of such ,code as a transaction specifically identified by the ,secretary on ,december #bc1 #bjaf1 as a tax avoidance transaction for purposes of section #fjaa of such ,code4 7d7 ,application to certain transactions disallowed under other provisions of law ,in the case of any disallowance of a deduction under section #agj of the ,internal ,revenue ,code of #aihf with respect a transaction described in ,internal ,revenue ,service ,notice #bjag-aj with respect to a taxable year ending before the date of the enactment of this ,act1 such disallowance shall be treated for purposes of section #fffb7;b77#aj7 of such ,code 7as added by this section7 and subsection 7c77#a7 as being by reason of section #agj7;h77#g7 of such ,code 7as added by this section74 7e7 ,effective date 7#a7 ,in general ,except as provided in paragraph 7#b71 the amendments made by this section shall apply to contributions made after ,december #bc1 #bjaf1 in taxable years ending after such date4 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 amendments 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