The Historic Preservation and Land Conservation Certainty Act establishes a voluntary settlement program for partnerships that have disputed conservation easement tax deductions with the IRS, allowing them to resolve these disputes without litigation by electing into the program within a 180-day window and paying a calculated settlement amount consisting of back taxes plus penalties capped at a multiple of their actual investment. Once a partnership files an election with Treasury and proper documentation, the settlement becomes immediately binding on all involved parties, who waive their right to contest the matter in court, though individual partners may still file refund claims and partnerships can request administrative review or Tax Court petitions within 90 days if the IRS disputes the computed amount. The bill also modifies the definition of "contributing buildings" in historic districts for tax purposes, allowing buildings to qualify based on identification in National Register nominations or district documentation rather than requiring individual certification by the Secretary of the Interior, with these changes applying retroactively to certain open tax years for conservation donations and prospectively for rehabilitation tax credits beginning after the law is enacted. The settlement program suspends IRS collection efforts during the review period, and the election remains valid if the additional amount is paid within 90 days after final determination.
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