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H.R. 4459House115th Congress (2017-2019)In Committee

Charitable Conservation Easement Program Integrity Act of 2017

Sponsored by Mike ThompsonRep. Mike Thompson (D-CA)
Introduced November 28, 2017

AI-Generated Summary

Updated April 15, 2026 at 7:15 PM UTC

The Charitable Conservation Easement Program Integrity Act of 2017 changes the tax rules for partnerships that make qualified conservation contributions. It limits how much a partner can deduct for such contributions, aiming to prevent overly large tax deductions. The rule applies to most partnerships, but not to family‑owned partnerships, and affects partners for the first five years they are in the partnership.

Key Provisions

  • Adds a new limitation to Section 170(h) of the Internal Revenue Code: a partner’s deduction for qualified conservation contributions cannot exceed 2.5 times the partner’s adjusted basis in the partnership for the tax year.
  • The limitation only applies during the partner’s first five taxable years after becoming a partner.
  • Provides an exception for family partnerships where most interests are held by related individuals, so the limitation does not apply to them.
  • Directs the Treasury Secretary to issue regulations to enforce the limitation and prevent avoidance.
  • Applies to contributions made after December 23, 2016.

Legislative Activity

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HouseIntro Referral Latest Action

Referred to the House Committee on Ways and Means.

Ways and Means Committee

November 28, 2017

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HouseIntro Referral

Introduced in House

November 28, 2017

HouseIntro Referral

Referred to the House Committee on Ways and Means.

Ways and Means Committee

November 28, 2017

Bill Text

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Introduced in HouseIssued November 28, 2017

I

115th CONGRESS

1st Session

H. R. 4459

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.

1.

Short title

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

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.