S. 170Senate116th Congress (2019-2021)In Committee

Charitable Conservation Easement Program Integrity Act of 2019

Introduced January 16, 2019

AI-Generated Summary

Updated April 14, 2026 at 12:28 AM UTC

The Charitable Conservation Easement Program Integrity Act of 2019 changes the tax rules for partnerships that make qualified conservation easement contributions. It limits how much a partner can deduct for those contributions, tying the deduction to the partner’s ownership stake in the partnership. The rule applies for the first three years a partner is in the partnership, with a special exemption for family‑owned partnerships.

Key Provisions

  • Adds a new paragraph to IRC §170(h) that caps a partner’s deduction for qualified conservation contributions at 2.5 times the partner’s adjusted basis in the partnership, measured at year‑end and ignoring the contribution itself.
  • The limitation only applies during the partner’s first three taxable years after becoming a partner.
  • Provides an exception for partnerships where almost all interests are held by related individuals (family partnerships).
  • Directs the Treasury Secretary to issue regulations to enforce the limitation and prevent avoidance.
  • Applies to contributions made in tax years ending after Dec. 23, 2016.

Legislative Activity

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1 earlier action
SenateIntro Referral Latest Action

Read twice and referred to the Committee on Finance.

January 16, 2019

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SenateIntro Referral

Introduced in Senate

January 16, 2019

SenateIntro Referral

Read twice and referred to the Committee on Finance.

January 16, 2019

Floor Debate

11 members

What members said about S. 170 on the floor

5 Republicans6 Democrats
Marco Rubio
Sen. Marco RubioR-FL · Jan 8, 2019

Mr. President, I ask unanimous consent that the order for the quorum call be rescinded. Mr. President, a few moments ago we welcomed our new colleague, my colleague for the State of Florida, former…

Tom Udall
Sen. Tom UdallD-NM · Jan 8, 2019

Mr. President, I rise to call on the President to stop holding the government hostage and trying to force taxpayers to pay for his border wall--a wall that would be ineffective and wasteful and that…

Patrick J. Leahy
Sen. Patrick J. LeahyD-VT · Jan 8, 2019

Mr. President, the Appropriations Committee has worked extremely hard to get these bills through. We passed them almost unanimously. Every single bill to keep this government open has been passed by…

Cory Gardner
Sen. Cory GardnerR-CO · Jan 8, 2019

Mr. President, to my colleague from South Carolina, Senator Graham, we will challenge the Clemson Tigers to the NCAA skiing championship anytime. I rise to speak about the bill we are working on…

James E. Risch
Sen. James E. RischR-ID · Jan 8, 2019

Mr. President and fellow Senators, I rise today to present S. 1, the Strengthening America's Security in the Middle East Act of 2019. It is really a compilation of three bills, addressing three…

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Mark R. Warner
Sen. Mark R. WarnerD-VA · Jan 8, 2019

Mr. President, I ask unanimous consent that Senator Kaine and I each be permitted to speak for up to 5 minutes prior to the scheduled vote. Mr. President, I want to join my colleagues from Maryland…

Chris Van Hollen
Sen. Chris Van HollenD-MD · Jan 8, 2019

Mr. President, we are now in day 18 of an unnecessary and shameful government shutdown. I am proud to be joined on the floor by my colleague and partner, the senior Senator from Maryland, Ben Cardin,…

Lindsey Graham
Sen. Lindsey GrahamR-SC · Jan 8, 2019

Mr. President, I will be quick. I know we have a lot to do before we vote, but if you are from South Carolina, you have a lot to be happy about today. If you watched the football game last night, I…

Benjamin L. Cardin
Sen. Benjamin L. CardinD-MD · Jan 8, 2019

Mr. President, I take this time to support what Senator Van Hollen has said. I am here with Senators Warner and Kaine. We have the honor of representing Maryland and Virginia in the Senate, where…

Tim Kaine
Sen. Tim KaineD-VA · Jan 8, 2019

Mr. President, before I begin, I ask unanimous consent that following my remarks, Senator Risch be permitted to speak for up to 5 minutes. Mr. President, tonight following this vote, Senator Shaheen…

Mitch McConnell
Sen. Mitch McConnellR-KY · Jan 8, 2019

I suggest the absence of a quorum. Mr. President, I enter a motion to reconsider the vote.

Bill Text

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Introduced in SenateIssued January 16, 2019

II

116th CONGRESS

1st Session

S. 170

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.

1.

Short title

This Act may be cited as the Charitable Conservation Easement Program Integrity Act of 2019.

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.