Rule2024-18925
Statutory Disallowance of Deductions for Certain Qualified Conservation Contributions Made by Partnerships and S Corporations; Correction
Primary source
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Published
August 30, 2024
Effective
August 30, 2024
Issuing agencies
Treasury DepartmentInternal Revenue Service
Abstract
This document contains corrections to Treasury Decision 9999, which was published in the Federal Register on Friday, June 28, 2024. The document issued final regulations concerning the statutory disallowance rule enacted by the SECURE 2.0 Act of 2022 to disallow a Federal income tax deduction for a qualified conservation contribution made by a partnership or an S corporation after December 29, 2022, if the amount of the contribution exceeds 2.5 times the sum of each partner's or S corporation shareholder's relevant basis.
Full Text
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<title>Federal Register, Volume 89 Issue 169 (Friday, August 30, 2024)</title>
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[Federal Register Volume 89, Number 169 (Friday, August 30, 2024)]
[Rules and Regulations]
[Pages 70486-70487]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2024-18925]
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DEPARTMENT OF THE TREASURY
Internal Revenue Service
26 CFR Part 1
[TD 9999]
RIN 1545-BQ90
Statutory Disallowance of Deductions for Certain Qualified
Conservation Contributions Made by Partnerships and S Corporations;
Correction
AGENCY: Internal Revenue Service (IRS), Treasury.
ACTION: Final rule; correction and correcting amendments.
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SUMMARY: This document contains corrections to Treasury Decision 9999,
which was published in the Federal Register on Friday, June 28, 2024.
The document issued final regulations concerning the statutory
disallowance rule enacted by the SECURE 2.0 Act of 2022 to disallow a
Federal income tax deduction for a qualified conservation contribution
made by a partnership or an S corporation after December 29, 2022, if
the amount of the contribution exceeds 2.5 times the sum of each
partner's or S corporation shareholder's relevant basis.
DATES: These corrections are effective on August 30, 2024. For dates of
applicability see Sec. Sec. 1.170A-14(o)(1), 1.170A-16(g)(2), 1.706-
3(e), and 1.706-4(e)(2)(xiii) and (e)(3)(ii).
FOR FURTHER INFORMATION CONTACT: Concerning these final regulations
under Sec. Sec. 1.170A-14, 1.706-3, and 1.706-4, contact John Hanebuth
or Benjamin Weaver at (202) 317-6850 (not a toll-free number);
concerning the final regulations under Sec. 1.170A-16 and issues
regarding section 170 of the Internal Revenue Code (Code) other than
section 170(h)(7), contact Elizabeth Boone at (202) 317-5100 or Hannah
Kim at (202) 317-7003 (not toll-free numbers).
SUPPLEMENTARY INFORMATION:
Background
The final regulations (TD 9999) that are the subject of this
correction are under sections 170 and 706 of the Code.
Corrections to Publication
Accordingly, FR Doc. 2024-13844 (TD 9999) appearing on page 54284
in the Federal Register on Friday, June 28, 2024, is corrected to read:
1. On page 54288, in the third column, in the sixth line of
footnote 2, the language ``determining relative basis'' is corrected to
read ``determining relevant basis''.
2. On page 54298, in the third column, the fifth line of the first
full paragraph is corrected to read ``extremely limited and that
ninety''.
3. On page 54309, in the first column, in the fourth line from the
bottom of the first partial paragraph the language ``1.170A-14(n)'' is
corrected to read ``1.170A-14(n)(4)''.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and recordkeeping requirements.
Corrections to the Regulations
Accordingly, 26 CFR part 1 is corrected by making the following
correcting amendments:
PART 1--INCOME TAXES
0
Paragraph 1. The authority citation for part 1 continues to read in
part as follows:
Authority: 26 U.S.C. 7805 * * *
Sec. 1.170A-14 [Corrected]
0
Par. 2. Section 1.170A-14 is amended by:
0
1. Removing ``$12.50'' in the first sentence of paragraph (m)(7)(ii)(E)
and adding ``$12.50X'' in its place;
0
2. Removing ``$19'' in the eleventh sentence of paragraph
(m)(7)(iii)(A) and adding ``$19X'' in its place;
0
3. Removing ``$26.80 ($26.80'' in paragraph (m)(7)(iii)(I) and adding
``$26.80X ($26.80X'' in its place;
0
4. Removing ``$1,000'' in paragraph (m)(7)(v)(A) and adding ``$1,000X''
in its place;
0
5. Removing ``$1,000'' in paragraph (m)(7)(v)(C)(2) and adding
``$1,000X'' in its place;
0
6. Removing the language ``$1,000 portion LossProp's adjusted basis
that does not exceed LossProp's $1,000X value, plus all of the $1,000''
in paragraph (m)(7)(v)(D)(2) and adding the language ``$1,000X portion
of LossProp's adjusted basis that does not exceed LossProp's $1,000X
value, plus all of the $1,000X'' in its place; and
0
7. Removing the word ``requirement'' in the third sentence of paragraph
(n)(2)(v)(B)(2) and adding the word ``requirements'' in its place.
0
Par 3. Section 1.170A-16 is amended by revising paragraph
(f)(6)(ii)(B)(1) to read as follows:
Sec. 1.170A-16 Substantiation and reporting requirements for noncash
charitable contributions.
* * * * *
(f) * * *
(6) * * *
(ii) * * *
(B) * * *
[[Page 70487]]
(1) Made by a contributing partnership (as defined in Sec. 1.170A-
14(j)(3)(iii)) or contributing S corporation (as defined in Sec.
1.170A-14(j)(3)(iv)); or
* * * * *
Oluwafunmilayo A. Taylor,
Section Chief, Publications & Regulations Section, Associate Chief
Counsel, (Procedure and Administration).
[FR Doc. 2024-18925 Filed 8-29-24; 8:45 am]
BILLING CODE 4830-01-P
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