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November 17, 2023

IRS releases proposed regulations disallowing certain charitable conservation contributions by partnerships and S corporations

The Treasury Department and IRS have released proposed regulations (REG-112916-23) that would disallow a tax deduction for a qualified conservation contribution made by a partnership or an S corporation after December 29, 2022, if the contribution is more than 2.5 times the sum of each partner's or S corporation shareholder's relevant basis. The proposed regulations would include definitions, methods to calculate the relevant basis, the three statutory exceptions to the statutory disallowance rule and reporting requirements. A Tax Alert is forthcoming.

Published by NTD’s Tax Technical Knowledge Services group; Andrea Ben-Yosef, legal editor