[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 [www.gpo.gov]
[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