This changes how partnerships and their partners can resolve IRS challenges to conservation-easement deductions, affecting taxes paid and litigation risk.
Creates a voluntary settlement election for partnerships that made conservation-easement donations (eligible contributions) with open IRS matters.
Limits the allowable deduction to a formula-based "settlement limitation amount" and makes payment of a computed settlement amount resolve federal income tax liability tied to the excess deduction.
Defines the settlement amount as a tax component (excess deduction × highest tax rate) plus a penalty component calculated under section 6662 rules.
Allows aggregation of partnerships in the same marketing/organizing chain into a single common marketing group and makes group members jointly and severally liable for the settlement amount.
Changes the tax code's "contributing building" standard: a contributing building is one identified as contributing in the National Register nomination or related official district documentation.
No hearings or votes scheduled.