Internal Revenue Bulletin 2024-30 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 2024–30
July 22, 2024
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Rev. Proc. 2024-29, page 121.
This procedure provides specifications for the private print-
ing of red-ink substitutes for the 2024 revisions of certain
information returns. This procedure will be reproduced as
the next revision of Publication 1179. Revenue Procedure
2023-30 is superseded.
INCOME TAX
Notice 2024-58, page 120.
This notice announces the applicable percentage under
§ 613A of the Internal Revenue Code to be used in deter-
mining percentage depletion for marginal properties for
the 2024 calendar year.
Rev. Proc. 2024-30, page 183.
This revenue procedure modifies Rev. Proc. 2024-23, 2024-
23 I.R.B. 1334, to provide procedures under § 446 of the
Internal Revenue Code and § 1.446-1(e) of the Income Tax
Regulations for obtaining automatic consent of the Commis-
sioner of Internal Revenue to change methods of accounting
to the Allowance Charge-off Method described in proposed
regulations under section 166. See Bad Debt Deductions
for Regulated Financial Companies and Members of Regu-
lated Financial Groups, 88 FR 89636 (Dec. 28, 2023).
T.D. 9999, page 72.
These are final regulations concerning the statutory dis-
allowance 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. These final
regulations provide guidance regarding this statutory disal-
lowance rule, including definitions, appropriate methods to
calculate the relevant basis of a partner or an S corporation
shareholder, the three statutory exceptions to the statutory
disallowance rule, and related reporting requirements. In
addition, these final regulations provide reporting require-
ments for partners and S corporation shareholders that
receive a distributive share or pro rata share of any noncash
charitable contribution made by a partnership or S corpo-
ration, regardless of whether the contribution is a qualified
conservation contribution (and regardless of whether the
contribution is of real property or other noncash property).
Finding Lists begin on page ii.

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Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing offi-
cial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rul-
ings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
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by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
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monthly indexes are cumulated on a semiannual basis, and are
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The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
July 22, 2024 Bulletin No. 2024–30

Part I
26 CFR 1.170A-14; 26 CFR 1.170A-16; 26 CFR
1.706-3; and 26 CFR 1.706-4
TD 9999
Statutory Disallowance
of Deductions for Certain
Qualified Conservation
Contributions Made
by Partnerships and S
Corporations
AGENCY: Internal Revenue Service
(IRS), Treasury.
ACTION: Final regulations.
SUMMARY: This document contains
final regulations concerning the statu-
tory disallowance rule enacted by the
SECURE 2.0 Act of 2022 to disallow a
Federal income tax deduction for a qual-
ified 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 share-
holder’s relevant basis. These final reg-
ulations provide guidance regarding this
statutory disallowance rule, including
definitions, appropriate methods to cal-
culate the relevant basis of a partner or
an S corporation shareholder, the three
statutory exceptions to the statutory dis-
allowance rule, and related reporting
requirements. In addition, these final
regulations provide reporting require-
ments for partners and S corporation
shareholders that receive a distributive
share or pro rata share of any noncash
charitable contribution made by a part-
nership or S corporation, regardless of
whether the contribution is a qualified
conservation contribution (and regard-
less of whether the contribution is of
real property or other noncash prop-
erty). These final regulations affect part-
nerships and S corporations that claim
qualified conservation contributions,
and partners and S corporation share-
holders that receive a distributive share
or pro rata share, as applicable, of a non-
cash charitable contribution.
DATES: Effective date: These regulations
are effective on June 28, 2024.
Applicability date: For dates of
applicability, see §§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 the final regu-
lations under §§1.170A-14, 1.706-3, and
1.706-4, contact John Hanebuth or Ben-
jamin Weaver at (202) 317-6850 (not a
toll-free number); concerning the final
regulations under §1.170A-16 and issues
regarding section 170 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
This document contains final regula-
tions amending the Income Tax Regula-
tions (26 CFR part 1) under sections 170
and 706 of the Internal Revenue Code
(Code) to implement the provisions of
section 605(a) and (b) of the SECURE 2.0
Act of 2022 (SECURE 2.0 Act), enacted
as Division T of the Consolidated Appro-
priations Act, 2023, Public Law 117-328,
136 Stat. 4459, 5393 (December 29,
2022), which apply to contributions of
property made after December 29, 2022.
I. Overview of Qualified Conservation
Contributions
Section 170(a) provides, subject to cer-
tain limitations and requirements, a deduc-
tion for any charitable contribution, as
defined in section 170(c), of cash or other
property the payment of which is made
within the taxable year. Section 170(f) dis-
allows charitable contribution deductions
in certain cases and provides special rules.
Section 170(f)(3)(A) provides that, in
the case of a contribution (not made by a
transfer in trust) of an interest in property
that consists of less than the taxpayer’s
entire interest in such property, a deduc-
tion will be allowed only to the extent that
the value of the interest contributed would
be allowable as a deduction under section
170 if such interest had been transferred
in trust. Section 170(f)(3)(B)(iii) provides
that section 170(f)(3)(A) does not apply to
a qualified conservation contribution.
II. Enactment of Section 170(f)(19) and
(h)(7)
Section 170(h)(7) was added to the
Code by section 605(a)(1) of the SECURE
2.0 Act. Section 170(h)(7)(A) states that
a contribution by a partnership (whether
directly or as a distributive share of a con-
tribution of another partnership) is not
treated as a qualified conservation contri-
bution for purposes of section 170 if the
amount of such contribution exceeds 2.5
times the sum of each partner’s relevant
basis in such partnership (Disallowance
Rule). Thus, a contribution of a qualified
real property interest to a qualified orga-
nization exclusively for conservation pur-
poses is not a qualified conservation con-
tribution if the Disallowance Rule applies.
Section 170(h)(7)(B)(i) provides that,
for purposes of section 170(h)(7), the term
“relevant basis” means, with respect to
any partner, the portion of such partner’s
modified basis in the partnership that is
allocable (under rules similar to the rules
of section 755 of the Code) to the portion
of the real property with respect to which
the contribution described in section
170(h)(7)(A) is made. Section 170(h)(7)
(B)(ii) provides that, for purposes of sec-
tion 170(h)(7), the term “modified basis”
means, with respect to any partner, such
partner’s adjusted basis in the partnership
as determined: (1) immediately before the
contribution described in section 170(h)
(7)(A), (2) without regard to section 752
of the Code, and (3) by the partnership
after taking into account these first two
adjustments and such other adjustments as
the Secretary of the Treasury or her dele-
gate (Secretary) may provide.
Section 170(h)(7)(F) provides that the
rules of section 170(h)(7) “apply to S cor-
porations and other pass-through entities
in the same manner as such rules apply to
partnerships,” except as the Secretary oth-
erwise provides.
Section 170(h)(7)(C) provides an
exception to the Disallowance Rule for
contributions that satisfy a three-year
July 22, 2024 72 Bulletin No. 2024–30

holding period. Section 170(h)(7)(D) pro-
vides an exception to the Disallowance
Rule for contributions from family pass-
through entities. Section 170(h)(7)(E)
provides an exception to the Disallowance
Rule for qualified conservation contribu-
tions the conservation purpose of which
is the preservation of a certified historic
structure.
Section 170(h)(7)(G) provides a spe-
cific grant of regulatory authority to the
Secretary to issue regulations or other
guidance as the Secretary determines
are necessary or appropriate to carry out
the purposes of the Disallowance Rule,
including reporting requirements and
rules to prevent the avoidance of the Dis-
allowance Rule.
Section 605(b) of the SECURE 2.0
Act added section 170(f)(19) to the Code,
which provides that, in the case of a part-
nership or S corporation claiming a qual-
ified conservation contribution for the
preservation of a building that is a certified
historic structure (as defined in section
170(h)(4)(C)) in an amount that exceeds
2.5 times the sum of each partner’s or S
corporation shareholder’s relevant basis
(as defined in section 170(h)(7)), no
deduction under section 170 is allowed
unless, as provided in section 170(f)(19)
(A)(i) and (ii), the partnership or S corpo-
ration includes on its return for the taxable
year a statement that such contribution
was made and any other information as
the Secretary may require. A contribution
to preserve a certified historic structure is
one of the three exceptions to the Disal-
lowance Rule.
Section 605(c) of the SECURE 2.0 Act
provides that the amendments made by
section 605 of the SECURE 2.0 Act apply
to contributions made after December 29,
2022, and that no inference is intended as
to the appropriate treatment of contribu-
tions made in taxable years ending on or
before that date, or as to any contribution
for which a deduction is not disallowed by
reason of section 170(h)(7).
III. The Proposed Regulations
On November 20, 2023, the Depart-
ment of the Treasury (Treasury Depart-
ment) and the IRS published a notice of
proposed rulemaking (REG-112916-23)
(the proposed regulations) in the Federal
Register (88 FR 80910) to provide guid-
ance under section 170(f)(19) and (h)(7).
The proposed regulations would make
changes to existing §1.170A-14, including
modifying paragraph (a) to reference the
Disallowance Rule and adding new para-
graphs (j) through (n) to §1.170A-14 to
provide guidance on the application of the
Disallowance Rule (and its exceptions) to
partnerships and S corporations. In addi-
tion, the proposed regulations would make
changes to the reporting requirements in
§1.170A-16. Finally, the proposed regu-
lations would make changes to §§1.706-3
and 1.706-4 to facilitate the operation of
the Disallowance Rule in the case of a
qualified conservation contribution made
by a partnership. The provisions of the
proposed regulations are explained in
greater detail in the preamble to the pro-
posed regulations.
Pursuant to section 7805(b)(2) of the
Code, regulations issued under section
170(f)(19) and (h)(7) within 18 months of
the December 29, 2022, date of enactment
of section 605 of the SECURE 2.0 Act
are permitted to apply to periods ending
before the dates provided under section
7805(b)(1) (generally, the dates of the
issuance of proposed or final regulations
or a notice describing the regulations).
Accordingly, the proposed regulations
under §§1.170A-14(j) through (n), 1.706-
3, and 1.706-4 were proposed to apply to
contributions made after December 29,
2022. To align the reporting requirements
under §1.170A-16 with the publication of
the revised Form 8283, Noncash Charita-
ble Contributions, and its instructions, the
proposed regulations under §1.170A-16
were proposed to apply to contributions
made in taxable years ending on or after
November 20, 2023 (the date the proposed
regulations were published in the Federal
Register).
Summary of Comments and
Explanation of Revisions
This Summary of Comments and
Explanation of Revisions summarizes the
proposed regulations and all the substan-
tive comments submitted in response to
the proposed regulations. The Treasury
Department and the IRS received eight
written comments in response to the pro-
posed regulations. The comments are
available for public inspection at https://
www.regulations.gov or upon request.
There were no requests to speak at the
scheduled public hearing. Consequently,
the public hearing was cancelled (89 FR
39). After full consideration of the com-
ments received, these final regulations
adopt the proposed regulations with mod-
ifications as described in this Summary of
Comments and Explanation of Revisions.
The comments can be grouped into
the following categories: (1) definitions,
(2) the computation of relevant basis, (3)
requests for guidance under the partner-
ship allocation rules, (4) the exceptions
to the Disallowance Rule, (5) reporting
requirements, and (6) other comments.
Each category is discussed in turn in the
remainder of this Summary of Comments
and Explanation of Revisions.
I. Definitions
Proposed §1.170A-14(j)(3) contained
definitions of terms, including “allocated
portion,” “amount of qualified conser-
vation contribution,” “contributing part-
nership,” “contributing S corporation,”
“direct interest,” “directly,” “disallowed
qualified conservation contribution,”
“indirect interest,” “indirectly,” “ultimate
member,” “upper-tier partnership,” and
“upper-tier S corporation.” Commenters
generally provided no comments on these
definitions, except with respect to the defi-
nition of the amount of qualified conser-
vation contribution. Thus, the final regu-
lations adopt the definitions as proposed,
except with respect to the definition of the
amount of qualified conservation contri-
bution.
Proposed §1.170A-14(j)(3)(ii) defined
“amount of qualified conservation con-
tribution” as the amount claimed as a
qualified conservation contribution on the
return of the contributing partnership or
contributing S corporation for the taxable
year in which the contribution is made.
No comments addressed the first sentence
of proposed §1.170A-14(j)(3)(ii), so the
final regulations adopt that sentence as
proposed.
Proposed §1.170A-14(j)(3)(ii) further
provided, “[i]f the contributing partner-
ship or contributing S corporation files an
amended return or administrative adjust-
ment request under section 6227 of the
Bulletin No. 2024–30 73 July 22, 2024

July 22, 2024 74 Bulletin No. 2024–30
Code claiming a different amount with
respect to the qualified conservation con-
tribution, the rules of [§1.170A-14] must
be re-applied with respect to such differ-
ent amount to determine the application
of section 170(h)(7) and [§1.170A-14.]”
One commenter stated that this sentence
would seem to inappropriately allow part-
nerships or S corporations to file admin-
istrative adjustment requests or amended
returns after they had been notified of an
IRS examination. The commenter recom-
mended that the regulations be changed
to refer only to an amended return or
administrative adjustment request that is
a “qualified amended return” for purposes
of the substantial underpayment rules.
The Treasury Department and the IRS
understand the commenter’s reference to
“qualified amended return” to be a refer-
ence to §1.6664-2(c)(3). Under §1.6664-
2(c)(3), a qualified amended return is an
amended return or a timely request for
an administrative adjustment under sec-
tion 6227, filed after the due date of the
return for the taxable year and before the
earliest of several dates, including the date
the taxpayer is first contacted by the IRS
concerning any examination with respect
to the return. Under section 6227(a), a
partnership may file an administrative
adjustment request for the amount of a
partnership-related item for any partner-
ship taxable year. However, under sec-
tion 6227(c), a partnership may not file
an administrative adjustment request after
a notice of an administrative proceeding
with respect to the taxable year is mailed
under section 6231 of the Code.
The Treasury Department and the IRS
did not intend the proposed regulations to
allow for the filing of an amended return
or administrative adjustment request in sit-
uations in which the partnership or S cor-
poration would not otherwise be allowed
to file an amended return or administrative
adjustment request. Moreover, the Trea-
sury Department and the IRS agree that the
re-application provision in §1.170A-14(j)
(3)(ii) should not be understood to allow a
partnership or S corporation to avoid the
Disallowance Rule by filing an amended
return or administrative adjustment
request claiming a lower amount with
respect to a qualified conservation con-
tribution after being contacted by the IRS
concerning an examination regarding the
return. For example, under an inappro-
priate interpretation of the language in
the proposed regulations, a contributing
S corporation could violate the Disallow-
ance Rule by claiming an amount of a
qualified conservation contribution on its
original return that exceeds 2.5 times the
sum of the relevant bases. Then, after its
return has been selected for examination
by the IRS, the contributing S corporation
could attempt to file an amended return on
which it reduces the amount of its claimed
qualified conservation contribution to an
amount not exceeding 2.5 times the sum
of the relevant bases. The contributing
S corporation could then argue that the
re-application provision in §1.170A-14(j)
(3)(ii) allows the Disallowance Rule to be
re-tested, and that, therefore, its qualified
conservation contribution is not disal-
lowed, but instead is allowed to the extent
of the amount claimed on the amended
return. In order to balance the need for a
mechanism to timely fix errors made in
good-faith with the risk of circumven-
tion of the Disallowance Rule, these final
regulations limit the re-application provi-
sion by providing that, if the contributing
partnership or contributing S corporation
files an amended return or timely admin-
istrative adjustment request under section
6227 of the Code claiming a lower amount
with respect to the qualified conservation
contribution, the rules of §1.170A-14 will
be re-applied with respect to such lower
amount to determine the application of sec-
tion 170(h)(7) and §1.170A-14 if and only
if the amended return or timely adminis-
trative adjustment request is filed before
the contributing partnership or contribut-
ing S corporation is put on notice of an
IRS examination relating to the qualified
conservation contribution. The final reg-
ulations provide that a contributing part-
nership or contributing S corporation is
considered to be on notice after the earlier
of: (1) the date the contributing partner-
ship or contributing S corporation is first
contacted by the IRS in connection with
any examination of a return that relates to
the qualified conservation contribution, or
(2) the date any person is first contacted
by the IRS concerning an examination of
that person under section 6700 (relating
to the penalty for promoting abusive tax
shelters) for an activity that relates to the
qualified conservation contribution. These
regulations do not incorporate the full
definition of qualified amended returns
within the meaning of §1.6664-2(c)(3)
as requested by the commenter, because
a definition tailored to the context of this
regulation is sufficient to prevent abusive
circumventions of the Disallowance Rule
without being overbroad and preventing
a contributing partnership or contributing
S corporation from being able to use the
re-application provision in non-abusive
situations.
In addition, the Treasury Department
and the IRS remain concerned about sit-
uations in which a contributing partner-
ship or contributing S corporation files
an amended return or administrative
adjustment request that claims a higher
amount with respect to a qualified conser-
vation contribution. In that situation, the
Treasury Department and the IRS have
concluded that the rules of §1.170A-14
should be re-applied with respect to such
higher amount to determine the applica-
tion of section 170(h)(7) and §1.170A-14
regardless of whether the amended return
or administrative adjustment request con-
stitutes a qualified amended return. This
rule is necessary to ensure that the Dis-
allowance Rule is not avoided simply
by filing an original return claiming an
amount with respect to a qualified conser-
vation contribution that does not exceed
2.5 times the sum of the relevant bases,
followed by an amended return or admin-
istrative adjustment request claiming an
amount with respect to the qualified con-
servation contribution that does exceed
2.5 times the sum of the relevant bases.
Accordingly, these final regulations mod-
ify the second sentence of §1.170A-14(j)
(3)(ii) to clarify that, if the contributing
partnership or contributing S corporation
files an amended return or administrative
adjustment request under section 6227 of
the Code claiming a higher amount with
respect to the qualified conservation con-
tribution, the rules of §1.170A-14 must
be re-applied with respect to such higher
amount to determine the application of
section 170(h)(7) and §1.170A-14; for
example, if a contributing S corporation’s
original return claims a qualified conser-
vation contribution that does not exceed
2.5 times the sum of the relevant bases,
and the S corporation subsequently files an
amended return claiming a higher amount

Bulletin No. 2024–30 75 July 22, 2024
with respect to the qualified conservation
contribution that does exceed 2.5 times
the sum of the relevant bases, then the
entire amount of the qualified conserva-
tion contribution is a disallowed qualified
conservation contribution (unless one of
the exceptions in §1.170A-14(n) applies).
II. Computation of Relevant Basis
As noted earlier, section 170(h)(7)
(B)(i) provides that, for purposes of sec-
tion 170(h)(7), the term “relevant basis”
means, with respect to any partner, the
portion of such partner’s modified basis
in the partnership that is allocable (under
rules similar to the rules of section 755 of
the Code) to the portion of the real prop-
erty with respect to which the contribu-
tion described in section 170(h)(7)(A) is
made. Proposed §1.170A-14(l) provided
guidance on the determination of modified
basis. Proposed §1.170A-14(m) provided
guidance on the allocation of modified
basis, which results in the determination
of relevant basis.
The Treasury Department and the IRS
received several comments on the compu-
tation of modified basis and relevant basis,
which can be divided into the following
two topics: (1) the determination of mod-
ified basis, and (2) the allocation of modi-
fied basis to determine relevant basis.
A. Determination of modified basis
As noted earlier, section 170(h)(7)(B)
(ii) provides that, for purposes of sec-
tion 170(h)(7), the term “modified basis”
means, with respect to any partner, such
partner’s adjusted basis in the partnership
as determined: (1) immediately before the
contribution described in section 170(h)
(7)(A), (2) without regard to section 752,
and (3) by the partnership after taking into
account those adjustments and such other
adjustments as the Secretary may provide.
Section 170(h)(7)(F) provides that the
rules of section 170(h)(7) “apply to S cor-
porations and other pass-through entities
in the same manner as such rules apply to
partnerships” except as the Secretary may
otherwise provide. This section of the pre-
amble discusses: (1) the proposed regula-
tions, comments, and final regulations for
the determination of a partner’s modified
basis, and (2) the proposed regulations,
comments, and final regulations for the
determination of an S corporation share-
holder’s modified basis.
1. Determination of a Partner’s Modified
Basis
a. Proposed rules for the determination of
a partner’s modified basis
Proposed §1.170A-14(l)(2)(i) defined
the term “modified basis” to mean, with
respect to any ultimate member that is
a direct partner in either a contributing
partnership or an upper-tier partnership,
such ultimate member’s adjusted basis in
its interest in the partnership in which the
ultimate member holds a direct interest as
of the beginning of the first day of the part-
nership’s taxable year in which the quali-
fied conservation contribution is made,
with adjustments as determined under
proposed §1.170A-14(l)(2)(ii) through
(v). However, if the ultimate member was
not a partner as of the beginning of the
first day of the partnership’s taxable year
in which the qualified conservation con-
tribution is made, then the term “modified
basis” means such ultimate member’s
adjusted basis in its interest in the partner-
ship immediately after the transaction that
resulted in the ultimate member becom-
ing a partner, with adjustments as deter-
mined under proposed §1.170A-14(l)(2)
(ii) through (v).
The proposed regulations provided
that the following four adjustments must
be made in the order in which they are
listed. First, proposed §1.170A-14(l)(2)
(ii) required an increase for any contribu-
tions made by the ultimate member to the
partnership during the portion of the year
commencing with the beginning of the
taxable year of the partnership and end-
ing immediately prior to the time of day
at which the qualified conservation contri-
bution is made as provided in section 722
of the Code.
Second, proposed §1.170A-14(l)(2)
(iii) required an adjustment, as provided
in section 705 of the Code, by the ultimate
member’s hypothetical distributive share
of partnership items attributable to the
portion of the year commencing with the
beginning of the taxable year of the part-
nership and ending immediately prior to
the time of day at which the qualified con-
servation contribution is made. In making
this determination, the partnership would
be required to apply the rules of §1.706-4
and apply a hypothetical interim closing
method to allocate the partnership’s items
attributable to the portion of the year com-
mencing with the beginning of the taxable
year of the partnership and ending imme-
diately prior to the time of day at which
the qualified conservation contribution is
made. The proposed regulations provided
that the partnership cannot apply any con-
vention in §1.706-4(c) to the hypothetical
determination of the partners’ distribu-
tive shares, but rather must perform the
calculation as though the determination
occurred immediately prior to the time
of day at which the qualified conserva-
tion contribution is made. The proposed
regulations clarified that this hypothetical
determination of the partners’ distributive
shares is only for purposes of calculating
modified basis. Proposed §1.170A-14(l)
(2)(iii) did not require the partnership
to use the interim closing method with
respect to the determination of its partners’
actual distributive shares of partnership
items of income, gain, loss, deduction,
and credit for the taxable year in which
the qualified conservation contribution is
made or otherwise.
Third, proposed §1.170A-14(l)(2)(iv)
required a reduction (but not below zero)
for any distributions made by the partner-
ship to the ultimate member during the
portion of the year commencing with the
beginning of the taxable year of the part-
nership and ending immediately prior to
the time of day at which the qualified con-
servation contribution is made as provided
in section 733 of the Code.
Fourth, proposed §1.170A-14(l)(2)(v)
required a reduction for the full amount of
the ultimate member’s share of §1.752-1
liabilities of any partnership (including
a lower-tier partnership). The remaining
amount would be such ultimate member’s
modified basis.
The proposed regulations contained
two examples illustrating these rules.
b. Comments concerning a partner’s
modified basis
The comments on the determination
of modified basis can be grouped into the
following three categories: (1) inclusion

July 22, 2024 76 Bulletin No. 2024–30
of section 752 liabilities in modified basis,
(2) determining modified basis immedi-
ately prior to the qualified conservation
contribution, and (3) the complexity of the
computations.
i. Inclusion of section 752 liabilities in
modified basis
Section 170(h)(7)(B)(ii)(II) provides
that modified basis is determined with-
out regard to section 752. Section 752(a)
provides that any increase in a partner’s
share of the liabilities of a partnership,
or any increase in a partner’s individual
liabilities by reason of the assumption by
such partner of partnership liabilities, is
considered as a contribution of money
by such partner to the partnership. Sec-
tion 752(b) provides that any decrease
in a partner’s share of the liabilities of
a partnership, or any decrease in a part-
ner’s individual liabilities by reason of
the assumption by the partnership of such
individual liabilities, is considered as a
distribution of money to the partner by the
partnership. Existing §1.752-1 provides
guidance under section 752, including a
definition of liabilities. Generally, under
the rules of subchapter K of chapter 1 of
the Code (subchapter K), if a partnership
borrows money, the aggregate bases of
its partners’ interests in the partnership
will increase by the amount of the bor-
rowing. Consistent with section 170(h)
(7)(B)(ii)(II), proposed §1.170A-14(l)(2)
(v) required subtracting the full amount
of the partner’s share of §1.752-1 liabili-
ties of any partnership (including a low-
er-tier partnership) for purposes of calcu-
lating modified basis.
One commenter expressed concern
that the relevant basis calculation ignores
section 752 liabilities generally. The com-
menter offered an example of a partner-
ship with $200,000 in cash that borrows
an additional $800,000 and purchases a
building for $1,000,000. The commenter
stated that the proposed regulations would
ignore the $800,000 as a section 752 lia-
bility and that any conservation contribu-
tion for historic preservation of the build-
ing would be capped at $500,000.
Section 170(h)(7)(B)(ii)(II) provides
that a partner’s modified basis (and thus,
relevant basis) is determined without
regard to section 752. The approach in the
proposed regulations appropriately effec-
tuates this statutory directive. Thus, in the
commenter’s example, although the part-
nership’s $800,000 liability will increase
the partners’ aggregate bases in their part-
nership interests by $800,000, none of that
$800,000 will be reflected in any partner’s
modified basis or relevant basis.
The commenter’s assumption that
the Disallowance Rule would cap the
amount of the partnership’s qualified
conservation contribution at $500,000
misunderstands the rule. Several other
considerations must be taken into account
to determine the extent of any allowable
qualified conservation contribution. First,
the Disallowance Rule is not a cap—as
explained in the preamble to the proposed
regulations and as provided in proposed
§1.170A-14(j)(1), if the amount of a qual-
ified conservation contribution claimed by
a partnership or an S corporation exceeds
2.5 times the sum of the relevant bases,
no deduction is allowed at all for the con-
tribution unless one of the three statutory
exceptions applies. Second, application of
the Disallowance Rule is not based on the
difference between the amount of the con-
tribution and the partnership’s basis in the
donated property; it is based on whether
the contribution exceeds 2.5 times the sum
of the ultimate members’ relevant bases.
The facts presented in the commenter’s
example are insufficient to determine
whether 2.5 times the sum of the relevant
bases is $500,000.
1

The same commenter also expressed
concerns that the proposed regulations
appear to treat the ultimate member’s
share of liabilities under §1.752-1(b) as
“flowing only in one direction” because
the proposed regulations provided that
modified basis must be reduced by the
full amount of the ultimate member’s
share of §1.752-1 liabilities of any part-
nership. The commenter stated that this
language ignores that a partner’s share
of liabilities may increase the partner’s
basis.
It is true that a partner’s share of the
partnership’s liabilities increases the part-
ner’s basis in its interest in the partnership.
However, this basis is not included for
purposes of the Disallowance Rule pursu-
ant to section 170(h)(7)(B)(ii)(II), which
requires modified basis to be determined
without regard to a partner’s share of the
partnership’s liabilities. Thus, these regu-
lations finalize §1.170A-14(l)(2)(v) with-
out change.
ii. Determining modified basis
immediately prior to the qualified
conservation contribution
One commenter stated that the pro-
posed regulations appear to time the cal-
culation of modified basis as of the time
of the qualified conservation contribution.
The commenter stated that this “artificial
cutoff” ignores any basis allocable to the
ultimate members following the contribu-
tion, such as from capital contributions or
increases in the ultimate members’ share
of section 752 liabilities.
The Treasury Department and the IRS
confirm that the rules in the proposed
regulations require the calculation of
modified basis (and thus, relevant basis)
as of the time of the qualified conserva-
tion contribution. As explained earlier,
the proposed regulations were intended
to effectuate section 170(h)(7)(B)(ii)(I),
which provides that modified basis is the
partner’s adjusted basis in the partnership
as determined “immediately before” the
qualified conservation contribution. The
Treasury Department and the IRS do not
agree with the commenter’s suggestion
that modified basis include amounts that
were reflected in the ultimate member’s
adjusted basis in its interest in the partner-
ship only after the contribution because
inclusion of such amounts would contra-
dict the statute. Thus, the proposed regu-
lations are adopted without change as to
this issue.
As a clarification to the statutory rule
that modified basis is determined imme-
diately before a qualified conservation
contribution is made, the final regulations
add a new step to the list of steps in pro-
1
Moreover, the commenter’s example seems to involve a qualified conservation contribution the conservation purpose of which is the preservation of a historic structure. If so, the Disallow-
ance Rule would not apply under section 170(h)(7)(E) and proposed §1.170A-14(n)(4), provided that, if the amount of the contribution exceeds 2.5 times the sum of the relevant bases, the
partnership or S corporation complies with the reporting requirements of section 170(f)(19) and proposed §1.170A-16(f)(6).

Bulletin No. 2024–30 77 July 22, 2024
posed §1.170A-14(l)(2). As described in
the preamble to the proposed regulations,
the proposed regulations were designed to
facilitate the computation of a partner’s
“adjusted basis” in its partnership interest
immediately prior to the qualified conser-
vation contribution. As also described in
the preamble to the proposed regulations,
adjusted basis is typically computed as of
the beginning or end of a taxable year, and
generally, not as of the time of a particular
event, such as the making of a qualified
conservation contribution. Accordingly,
the approach in the proposed regulations
started with a calculation of adjusted basis
that partners are familiar with computing,
and then made adjustments designed to
arrive at an amount that reflects the part-
ner’s adjusted basis immediately before
the qualified conservation contribution.
The proposed regulations did not, how-
ever, take into account acquisitions of
additional partnership interests or partial
dispositions of partnership interests that
occurred after the beginning of the taxable
year and prior to the qualified conserva-
tion contribution. In those situations, an
additional step is necessary to effectuate
the rule in section 170(h)(7)(B)(ii) that
modified basis is adjusted basis imme-
diately before the qualified conservation
contribution without regard to section
752. The new step, in §1.170A-14(l)(2)
(iii), provides that if, between the begin-
ning of the partnership’s taxable year and
the time of day at which the qualified con-
servation contribution is made, the ulti-
mate member acquired additional interests
in the partnership, modified basis must be
increased by the ultimate member’s initial
basis in those additional interests. Simi-
larly, §1.170A-14(l)(2)(iii) provides that
if, between the beginning of the partner-
ship’s taxable year and the time of day at
which the qualified conservation contri-
bution is made, the ultimate member par-
tially disposed of its interest in the part-
nership, modified basis must be decreased
by the ultimate member’s basis in the
interests disposed of. The final regulations
add §1.170A-14(l)(4)(iv) (Example 4) to
illustrate this step.
iii. Complexity of the determination of
modified basis
Multiple commenters stated that
the proposed regulations’ calculations,
including the calculation of modified
basis, were too complex.
2
One com-
menter stated that the proposed reg-
ulations are well drafted and that the
mechanical rules work, but that the
computations are too complex. Another
commenter stated that the calculations
were complex and would be difficult for
taxpayers, land trusts, and even the IRS
to administer. Another commenter stated
that the proposed rules are unnecessarily
complex and will likely discourage many
partnerships from making conservation
contributions even if, after performing
the calculations, the contribution would
not be disallowed by the Disallowance
Rule. Finally, another commenter found
the regulations to be a “complex laby-
rinth” in which one misstep leads to the
disallowance of the charitable deduction
and imposition of the gross overvaluation
penalty under section 6662(h) and also
places a significant burden on the IRS and
the Independent Office of Appeals. This
commenter suggested that, under Exec-
utive Order 12866, 58 FR 190 (October
4, 1993), and Internal Revenue Manual
provision 32.1.4.1.1(1)(a), the Treasury
Department and the IRS are required to
draft regulations to minimize litigation,
but that the proposed regulations likely
will increase litigation as the regulations
are overly complex and burdensome for
the average taxpayer.
As an alternative to the complexity in
the proposed regulations, one commenter
suggested that the IRS develop simplified
safe harbor calculations. Another com-
menter suggested applying pure aggre-
gate rules to the contributing partnership
and any upper-tier partnerships to deter-
mine modified basis and relevant basis
and adding an anti-abuse rule that the
transaction does not work if a principal
purpose is to avoid the limitations of sec-
tion 170(h)(7). This commenter noted,
however, that this suggestion was less
precise and subject to potential abuse,
but stated that it is a rule that even small
practitioners could apply.
These suggested approaches are not
specific or accurate enough to comply
with the statutory directive of section
170(h)(7). Section 170(h)(7)(B)(ii)(I)
through (III) provides that modified basis
is the partner’s adjusted basis in the part-
nership immediately before the quali-
fied conservation contribution, without
regard to section 752. Partners generally
do not track their bases in their partner-
ship interests on a daily basis. Instead,
such determinations are typically made
at year end. Thus, a partnership gener-
ally will not know each partner’s basis
in its partnership interest as of a partic-
ular point during the year, such as the
moment at which the partnership makes
a qualified conservation contribution. A
partnership required by section 170(h)
(7)(B)(ii)(III) to compute modified basis
would generally have to start with each
partner’s adjusted basis in its partnership
interest as of the beginning of the year
3

and make certain adjustments for items
or events occurring in the portion of the
year ending with the qualified conserva-
tion contribution that affect basis. These
are the very steps that were prescribed
by the proposed regulations. Each of the
steps from the proposed regulations is
necessary to carry out the statutory direc-
tive that a partner’s modified basis is the
partner’s adjusted basis in its partnership
interest immediately before the time of
the qualified conservation contribution, as
computed by the partnership, and without
regard to section 752 liabilities. Instead of
simply repeating the statutory mandate,
the proposed regulations provided a clear,
administrable, step-by-step approach for
taxpayers to reach the result required by
the statute. To assist with performing the
computations required by this step-by-
step approach, the proposed regulations
included several illustrative examples.
Accordingly, proposed §1.170A-14(l)(2)
is finalized with the changes described in
this Part II.A.1 of this Summary of Com-
ments and Explanation of Revisions.
2
It is unclear from the comments whether some commenters were objecting to the complexity of the determination of modified basis, the determination of relevant basis (once modified basis
is determined), or both. Comments addressing the complexity of determining relevant basis once modified basis is determined are discussed in Parts II.B.1.a, II.B.2, II.B.3.a, and II.B.4.a of
this Summary of Comments and Explanation of Revisions.
3
In the case of a partner who was not a partner at the beginning of the year, but acquired an interest sometime later, the partnership would generally have to start with the partner’s adjusted
basis in its partnership interest as of the time of the acquisition of that interest. This is the process that these regulations provide.

July 22, 2024 78 Bulletin No. 2024–30
2. Determination of an S Corporation
Shareholder’s Modified Basis
a. Proposed rules for the determination of
an S corporation shareholder’s modified
basis
Proposed §1.170A-14(l)(3)(i) provided
that the term “modified basis” means,
with respect to any ultimate member that
is a shareholder in an S corporation, such
ultimate member’s adjusted basis in its
shares in the S corporation as of the end of
the S corporation’s taxable year in which
the qualified conservation contribution
is made with adjustments as determined
under proposed §1.170A-14(l)(3)(ii) and
(iii). However, if the ultimate member
was not a shareholder at the end of the S
corporation’s taxable year in which the
qualified conservation contribution is
made, then the term “modified basis” was
defined to mean such ultimate member’s
adjusted basis in its shares in the S corpo-
ration immediately prior to the transaction
that terminated its interest in the S cor-
poration, with adjustments as determined
under proposed §1.170A-14(l)(3)(ii) and
(iii). Consistent with the exclusion of sec-
tion 752 liabilities under section 170(h)
(7)(B)(ii)(II), proposed §1.170A-14(l)(3)
(i) clarified that modified basis does not
include the ultimate member’s adjusted
basis in any indebtedness of the S corpo-
ration to the ultimate member.
Because the calculation of modified
basis for an S corporation begins at the
end of the year, proposed §1.170A-14(l)
(3)(ii) required the computation of mod-
ified basis to be increased by the amount
of any decrease to the adjusted basis as a
result of the qualified conservation contri-
bution. Thus, the ultimate member’s mod-
ified basis with respect to a qualified con-
servation contribution would not reflect
any reduction for the ultimate member’s
pro rata share of the S corporation’s basis
in the conservation easement or other
property contributed in the qualified con-
servation contribution.
Proposed §1.170A-14(l)(3)(iii) pro-
vided that the amount determined under
§1.170A-14(l)(3)(ii) must be multiplied
by the number of days during the S corpo-
ration’s taxable year in which the ultimate
member was a shareholder and divided
by the total number of days during the S
corporation’s taxable year. The resulting
amount would be such ultimate member’s
modified basis.
The proposed regulations contained an
example illustrating these rules.
b. Comments concerning modified basis
for S corporation shareholders
Commenters did not provide spe-
cific comments concerning the rules for
S corporation shareholders; however, as
described in Part II.A.1.b of this Sum-
mary of Comments and Explanation of
Revisions, certain commenters discussed
complexity concerns with respect to mod-
ified basis without specifically identifying
partnerships, so those comments may also
apply to S corporations. The Treasury
Department and the IRS have determined
that the rules for determining modified
basis for S corporation shareholders are
not unduly complex. In particular, any
of the information required to determine
modified basis should be readily known
by a contributing S corporation and its
ultimate members. The regulations pro-
vide clear, administrable rules that are
illustrated with computational examples.
This clarity will help decrease disputes
about the computation of modified basis.
Accordingly, these final regulations do not
make changes to the rules for the determi-
nation of modified basis in response to the
commenters’ concerns about complexity
and proposed §1.170A-14(l)(3) is final-
ized without change.
B. Allocation of modified basis to
determine relevant basis
Proposed §1.170A-14(m) provided
rules for determining relevant basis, which
is the portion of modified basis that is allo-
cable to the portion of the real property
with respect to which the qualified con-
servation contribution is made. In general,
the proposed regulations provided that
relevant basis is modified basis multiplied
by a fraction, the numerator of which is
the ultimate member’s portion of the basis
in the real property with respect to which
the qualified conservation contribution is
made, and the denominator of which is the
ultimate member’s portion of the basis in
all properties held by the partnership or
S corporation. For example, if an ultimate
member’s share of the basis in the real
property is half of the ultimate member’s
share of the basis in the other properties
of the partnership or S corporation, the
ultimate member’s relevant basis would
be half of the ultimate member’s modified
basis. The proposed regulations contained
rules for these computations, including
rules for the computation of relevant basis
in tiered entities. The proposed regula-
tions also contained additional details and
several examples of the computation of
relevant basis.
The proposed regulations provided
separate rules for the determination of rel-
evant basis for ultimate members who are:
(1) partners in contributing partnerships,
(2) shareholders in contributing S corpo-
rations, (3) partners in upper-tier partner-
ships, and (4) shareholders in upper-tier
S corporations. The following portion of
this Summary of Comments and Explana-
tion of Revisions will discuss each set of
rules in turn.
1. Determination of Relevant Basis for
Partners in Contributing Partnerships
Proposed §1.170A-14(m)(2)(i) through
(iii) provided that the relevant basis of an
ultimate member holding a direct interest
in a contributing partnership is equal to the
ultimate member’s modified basis as deter-
mined under proposed §1.170A-14(l)(2)
multiplied by a fraction: (1) the numerator
of which is the ultimate member’s share
of the contributing partnership’s adjusted
basis in the portion of the real property
with respect to which the qualified conser-
vation contribution is made as determined
under proposed §1.170A-14(m)(2)(ii);
and (2) the denominator of which is the
ultimate member’s portion of the adjusted
basis in all the contributing partnership’s
properties as determined under proposed
§1.170A-14(m)(2)(iii).
For purposes of this computation, pro-
posed §1.170A-14(m)(2)(ii) provided that
an ultimate member’s share of the contrib-
uting partnership’s adjusted basis in the
portion of the real property with respect
to which the qualified conservation con-
tribution is made equals the contributing
partnership’s adjusted basis in the portion
of the real property with respect to which
the qualified conservation contribution is
made (determined as of the time of day of

Bulletin No. 2024–30 79 July 22, 2024
the contribution) multiplied by a fraction:
(1) the numerator of which is the ultimate
member’s distributive share of the quali-
fied conservation contribution; and (2) the
denominator of which is the total amount
of the contributing partnership’s qualified
conservation contribution.
Proposed §1.170A-14(m)(2)(iii) pro-
vided that an ultimate member’s portion
of the adjusted basis in all the contribut-
ing partnership’s properties is equal to the
sum of: (1) the ultimate member’s share
of the contributing partnership’s adjusted
basis in the portion of the real property
with respect to which the qualified con-
servation contribution is made as deter-
mined under proposed §1.170A-14(m)(2)
(ii), and (2) the ultimate member’s portion
of the adjusted basis in all the contribut-
ing partnership’s properties other than the
portion of the real property with respect
to which the qualified conservation contri-
bution is made. To determine an ultimate
member’s share of the adjusted basis in all
the contributing partnership’s properties,
the proposed regulations provided that a
contributing partnership must apportion
among each of its partners in accordance
with their interests in the partnership under
section 704(b) of the Code the partner-
ship’s adjusted basis in each of its prop-
erties (except the portion of the real prop-
erty with respect to which the qualified
conservation contribution is made), using
the adjusted bases immediately before the
qualified conservation contribution, with-
out duplication or omission of any prop-
erty, and by treating the adjusted basis in
each property as not less than zero.
Proposed §1.170A-14(m)(2)(iv) pro-
vided the following formula incorporating
these rules:
R = M × (T ÷ (D + T))
Where:
R = Relevant basis.
M = Modified basis as determined
under proposed §1.170A-14(l).
D = Ultimate member’s portion of
the adjusted basis in all the con-
tributing partnership’s properties
(other than the portion of the real
property with respect to which
the qualified conservation contri-
bution is made), determined by
apportioning among the partners
of the contributing partnership
in accordance with their inter-
ests in the partnership under sec-
tion 704(b) its adjusted basis in
each of its properties (other than
the portion of the real property
with respect to which the quali-
fied conservation contribution is
made), using the adjusted bases
immediately before the qualified
conservation contribution, with-
out duplication or omission of
any property, and by treating the
adjusted basis in each property as
not less than zero.
T = Ultimate member’s share of
the contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made, determined
according to the following for-
mula: A × (B ÷ C).
A = Contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made.
B = Ultimate member’s distributive
share of the qualified conservation
contribution.
C = Total amount of the contributing
partnership’s qualified conserva-
tion contribution.
The comments received on the alloca-
tion of modified basis can be grouped into
the following two categories: (a) com-
plexity, and (b) the effect of section 704(c)
property. Each category is discussed in
turn.
a. Complexity of the proposed rules for
the allocation of modified basis
As noted in Part II.A.1.b.iii. of this
Summary of Comments and Explanation
of Revisions, multiple commenters stated
that the calculations in the proposed regu-
lations were too complex. One commenter
stated that the Treasury Department and
the IRS should reconsider the computa-
tional proposals and develop “simplified
safe harbor calculations” to give taxpayers
the assurance that they have done the math
correctly and will not unintentionally
incur additional tax and significant pen-
alties. As mentioned previously, one com-
menter who objected to the complexity of
the calculations proposed an alternative
method of applying pure aggregate rules
to the contributing partnership and any
upper-tier partnerships to determine mod-
ified basis and relevant basis. The com-
menter described this alternative as “sim-
ple” and suggested adding an anti-abuse
rule if a principal purpose is to avoid the
limitations of section 170(h)(7), but also
acknowledged that this approach was “[l]
ess precise and subject to potential abuse.”
Other commenters, while stating that the
proposed regulations were complex, did
not express any alternative suggestions.
The rules in the proposed regulations
for the allocation of modified basis to
determine relevant basis are not inappro-
priately complex in light of the statute
which they administer. Section 170(h)
(7)(B)(i) directs that modified basis be
allocated to the portion of the real prop-
erty with respect to which the qualified
conservation contribution is made under
rules similar to the rules of section 755.
As mentioned in the preamble to the pro-
posed regulations, the section 755 regula-
tions involve several different methods for
allocating basis adjustments among the
partnership’s properties, including allo-
cating in proportion to the partner’s share
of the adjusted bases in the partnership’s
properties. See §1.755-1(b)(5)(iii)(B).
The section 755 regulations contain math-
ematical examples illustrating these rules,
formulas, and computations and also addi-
tional rules and exceptions.
As explained in the preamble to
the proposed regulations, the Treasury
Department and the IRS considered sim-
ply cross-referencing the rules under
section 755. However, allocations under
section 755 are sometimes made in a way
to reduce or eliminate built-in gain or
built-in loss in partnership property. The
relevant basis rule of section 170(h)(7)(B)
(i) is designed to determine the portion of
a partner’s modified basis that is alloca-
ble to the portion of the real property with
respect to which the contribution is made,
which is a broader and, generally, differ-
ent concept than determining the partner’s
share of built-in gain or built-in loss in
that property. Thus, applying an approach
based solely on the existing section 755
regulations would not be consistent with

July 22, 2024 80 Bulletin No. 2024–30
the purpose of the Disallowance Rule.
Moreover, these regulations for the allo-
cation of modified basis are similar to, and
not more complex than, the rules of sec-
tion 755.
Section 170(h)(7) is computational in
nature. Although the statute is relatively
short and does not list any formulas, com-
plying with section 170(h)(7)(B)(i) nec-
essarily involves computations involving
every asset owned by the partnership or
S corporation and any lower-tier partner-
ships. The proposed regulations acknowl-
edged this complexity and, if possible,
sought to simplify the requirements and
provide clear guidance. Thus, the proposed
regulations are not more complex than the
statutory language already requires.
Furthermore, partnerships and S cor-
porations making qualified conservation
contributions are required by existing
rules to track each partner’s and share-
holder’s share of the entity’s basis in the
contributed property. See sections 704(d)
(3), 705(a)(2), 1366(d)(4), and 1367(a)(2)
of the Code; Rev. Rul. 96-11, 1996-1 C.B.
140; Rev. Rul. 2008-16, 2008-1 C.B. 585.
Additionally, in certain circumstances the
rules under section 755 require a partner-
ship to calculate a partner’s share of the
partnership’s basis in its properties. Thus,
the approach taken by the proposed reg-
ulations is consistent with existing rules
and principles.
The Treasury Department and the IRS
have considered the commenter’s recom-
mendation of determining relevant basis
based on a “pure aggregate” approach,
subject to an anti-abuse rule or some type
of safe harbor. The Treasury Department
and the IRS agree with the commenter’s
assessment that such an approach would
be less clear and more subject to abuse.
As explained in the preamble to the pro-
posed regulations, Congress enacted the
Disallowance Rule because of abusive
syndicated conservation easement trans-
actions. It would not be appropriate to
deviate from the computational require-
ments of the statute. Congress intended
that partnerships and S corporations that
make qualified conservation contributions
perform several calculations to substanti-
ate that the contribution is not disallowed
by the Disallowance Rule. Allowing for
shortcuts to such calculations that lead to
less accurate results would be inconsistent
with Congress’s purpose in enacting the
Disallowance Rule. Moreover, the compu-
tational step-by-step approach in the pro-
posed regulations will minimize litigation
by providing clear, administrable guid-
ance. A shorter, more conceptually-based
rule such as “safe harbor” calculations
or “pure aggregate treatment” would be
less clear and would lead to additional
disputes over the proper computation of
relevant basis.
In sum, the Treasury Department and
the IRS have determined that the approach
in the proposed regulations is similar to
the rules of section 755, consistent with
the rule of section 170(h)(7)(B)(i), and
consistent with the purposes of the Disal-
lowance Rule. Accordingly, the Treasury
Department and the IRS do not adopt the
approaches suggested by commenters.
b. Effect of section 704(c) on the
allocation of modified basis
As noted earlier, the proposed regu-
lations allocate modified basis by refer-
ence, in part, to the partners’ interests in
the partnership, which is a concept under
section 704(b). Specifically, under pro-
posed §1.170A-14(m)(2)(iii)(B), to deter-
mine a partner’s portion of the adjusted
basis in all the contributing partnership’s
properties, the contributing partnership
would apportion among its partners in
accordance with their interests in the part-
nership under section 704(b) its adjusted
basis in each of its properties (except the
portion of the real property with respect
to which the qualified conservation contri-
bution is made), using the adjusted bases
immediately before the qualified conser-
vation contribution, without duplication
or omission of any property, and by treat-
ing the adjusted basis in each property as
not less than zero.
The proposed regulations did not
explicitly address the impact of section
704(c) amounts. One commenter stated
that, to promote transparency, the final
regulations should discuss what impact, if
any, section 704(c) may have with respect
to conservation easement transactions in
the context of section 170(h)(7).
In part, section 704(c) provides rules
for partnership allocations with respect
to property that has built-in gain (that is,
fair market value in excess of adjusted
basis) or built-in loss (that is, adjusted
basis in excess of fair market value) at
the time the property is contributed by a
partner to the partnership (section 704(c)
property). Section 704(c)(1)(A) provides
that, under regulations prescribed by the
Secretary, income, gain, loss, and deduc-
tion with respect to property contributed
to the partnership by a partner is shared
among the partners so as to take account
of the variation between the basis of the
property to the partnership and its fair
market value at the time of contribution.
If a partner contributes property with
built-in gain or built-in loss to a partner-
ship, and the partnership subsequently
sells the property and recognizes that
gain or loss, the regulations under section
704(c)(1)(A) generally require the part-
nership to allocate that gain or loss to the
contributing partner.
The Treasury Department and the
IRS agree that it may be unclear how
the presence of section 704(c) property
affects the partnership’s apportionment
of its basis in its properties among its
partners for purposes of the computa-
tion of relevant basis, and that the final
regulations should provide additional
guidance on how section 704(c) property
affects the computation of relevant basis.
Thus, §1.170A-14(m)(2)(iii)(B) as final-
ized in this Treasury Decision provides
that to determine a partner’s portion of
the adjusted basis in all of a contributing
partnership’s properties, the contribut-
ing partnership must apportion among
its partners its adjusted basis in each of
its properties (except the portion of the
real property with respect to which the
qualified conservation contribution is
made), using the adjusted basis imme-
diately before the qualified conserva-
tion contribution, without duplication or
omission of any property, and by treating
the adjusted basis in each property as not
less than zero. Consistent with the pro-
posed regulations, these final regulations
provide that this apportionment must
be done under principles similar to the
determination of the partners’ interests
in the partnership under section 704(b),
but add a cross reference to §1.704-1(b)
(3)(ii), which provides factors to con-
sider in determining a partner’s interest
in a partnership. These factors include:
the partners’ relative contributions to the

Bulletin No. 2024–30 81 July 22, 2024
partnership, the interests of the partners
in economic profits and losses (if differ-
ent than that in taxable income or loss),
the interests of the partners in cash flow
and other non-liquidating distributions,
and the rights of the partners to distri-
butions of capital upon liquidation. In
addition, §1.170A-14(m)(2)(iii)(B) as
finalized provides that the apportionment
must reflect section 704(c) principles.
For example, if a partnership property
has built-in loss (the adjusted basis of the
property exceeds its fair market value),
and section 704(c) would require that
built-in loss to be allocated to a certain
partner if that property were sold, all of
the basis in the property that exceeds
the property’s fair market value must be
apportioned to the partner to whom the
loss would be allocated if the property
was sold.
The final regulations contain two
examples illustrating the effect of sec-
tion 704(c) property upon the computa-
tion of relevant basis. In the first example
(§1.170A-14(m)(7)(iv) (Example 4)), one
partner contributes property with built-in
gain to the partnership. The partnership
later makes a qualified conservation con-
tribution with respect to other property.
The example shows how the partnership’s
basis in the built-in gain property is appor-
tioned among the partners for the purposes
of determining relevant basis.
The second example (§1.170A-14(m)
(7)(v) (Example 5)) involves the same
facts, except that the property contrib-
uted to the partnership has built-in loss
instead of built-in gain. The example
shows how the basis in the built-in-loss
property is apportioned among the part-
ners for the purposes of determining rel-
evant basis.
The change to §1.170A-14(m)(2)(iii)
(B) is also reflected in the formulaic ver-
sion of the rule in §1.170A-14(m)(2)(iv)
in these final regulations. Specifically,
item D is modified to read:
D = Ultimate member’s portion of
the adjusted basis in all the con-
tributing partnership’s properties
(other than the portion of the real
property with respect to which the
qualified conservation contribu-
tion is made) as determined under
§1.170A-14(m)(2)(iii)(B).
2. Determination of Relevant Basis for
Ultimate Members That Are Shareholders
in a Contributing S Corporation
Proposed §1.170A-14(m)(3)(i) pro-
vided that relevant basis for an ultimate
member holding a direct interest in a con-
tributing S corporation would equal the
ultimate member’s modified basis multi-
plied by a fraction: (1) the numerator of
which is the ultimate member’s pro rata
portion of the contributing S corporation’s
adjusted basis in the portion of the real
property with respect to which the qual-
ified conservation contribution is made;
and (2) the denominator of which is the
ultimate member’s pro rata portion of
the adjusted basis in all the contributing
S corporation’s properties (including the
portion of the real property with respect
to which the qualified conservation contri-
bution is made). Proposed §1.170A-14(m)
(3)(ii) provided the following formulaic
version of this rule:
R = M × (E ÷ F)
Where:
R = Relevant basis.
M = Modified basis as determined
under §1.170A-14(l).
E = Ultimate member’s pro rata por-
tion of the contributing S corpora-
tion’s adjusted basis in the portion
of the real property with respect to
which the qualified conservation
contribution is made.
F = Ultimate member’s pro rata por-
tion of the adjusted basis in all
the contributing S corporation’s
properties (including the portion
of the real property with respect
to which the qualified conserva-
tion contribution is made).
Commenters did not raise issues spe-
cifically concerning the formula for
S corporations but did express concerns
regarding the complexity of proposed
§1.170A-14(m) in general. In the view of
the Treasury Department and the IRS, this
formula accurately accounts for modified
basis as a portion of the real property by
simply taking the pro rata allocation of
adjusted basis in the contributed property
over the pro rata allocation of adjusted
basis in all the S corporation’s properties
and is not more complex than necessary
to carry out the purposes of the Disallow-
ance Rule.
The Treasury Department and the IRS
considered several alternatives to this rule.
One method would be to require a deter-
mination of a portion of relevant basis for
every day during the S corporation’s tax-
able year, because S corporations gener-
ally allocate the contribution on a pro rata
basis among the shareholders on each day
of the taxable year. These final regulations
do not take that approach because such an
approach, although technically accurate
and consistent with the purposes of the
Disallowance Rule, would be too burden-
some for taxpayers and difficult for the
IRS to administer.
Accordingly, these final regulations
finalize proposed §1.170A-14(m)(3) with-
out change.
3. Determination of Relevant Basis for
Partners in Upper-Tier Partnerships
Proposed §1.170A-14(m)(4) provided
rules for determining the relevant basis of
an ultimate member holding a direct inter-
est in an upper-tier partnership. Proposed
§1.170A-14(m)(4)(i) provided that each
such ultimate member’s modified basis
must be traced through all upper-tier part-
nerships to the contributing partnership,
and the contributing partnership must
determine the relevant basis. This would
involve a multi-step process under which,
beginning with the upper-tier partnership
in which the ultimate member holds a
direct interest, each upper-tier partnership
would be required to perform calculations,
and then finally the contributing partner-
ship would be required to use those calcu-
lations to compute the ultimate member’s
relevant basis.
Proposed §1.170A-14(m)(4)(ii)
(A) provided that the upper-tier part-
nership must determine the portion of
each ultimate member’s modified basis
that is allocable to the upper-tier part-
nership’s interest in the partnership in
which it holds a direct interest (in a
situation involving only two tiers of
partnerships, that will be the contrib-
uting partnership). This determination
must be done in accordance with the
principles of proposed §1.170A-14(m)
(2) and the formula provided in pro-

July 22, 2024 82 Bulletin No. 2024–30
posed §1.170A-14(m)(4)(ii)(B). In
other words, the formula provided in
proposed §1.170A-14(m)(4)(ii)(B) is
similar to the formula provided in pro-
posed §1.170A-14(m)(2)(iv), except
that, instead of determining the por-
tion of modified basis that is allocable
to the portion of the real property with
respect to which the qualified conser-
vation contribution is made, the for-
mula in proposed §1.170A-14(m)(4)(ii)
(B) determines the portion of modified
basis that is allocable to the upper-tier
partnership’s interest in the next low-
er-tier partnership. As explained in
proposed §1.170A-14(m)(4)(iii), the
contributing partnership will then use
the amount determined under the for-
mula in proposed §1.170A-14(m)(4)(ii)
(B) to compute the portion of modified
basis that is allocable to the portion of
the real property with respect to which
the qualified conservation contribution
is made.
Proposed §1.170A-14(m)(4)(ii)(B)
provided the following formula:
G = M × (U ÷ (J + U))
Where:
G = The portion of the ultimate mem-
ber’s modified basis that is alloca-
ble to the upper-tier partnership’s
interest in the contributing part-
nership.
M = Modified basis as determined
under §1.170A-14(l).
J = Ultimate member’s portion of the
adjusted basis in all the upper-tier
partnership’s properties (other than
the upper-tier partnership’s interest
in the contributing partnership),
determined by apportioning among
the partners of the upper-tier part-
nership in accordance with their
interests in the partnership under
section 704(b) its adjusted basis in
each of its properties (other than
the upper-tier partnership’s interest
in the contributing partnership),
using the adjusted bases immedi-
ately before the qualified conser-
vation contribution, without dupli-
cation or omission of any property,
and by treating the adjusted basis
in each property as not less than
zero.
U = Ultimate member’s share of the
upper-tier partnership’s adjusted
basis in its interest in the con-
tributing partnership, determined
according to the following for-
mula: H × (B ÷ K).
H = Upper-tier partnership’s adjusted
basis in its interest in the contrib-
uting partnership.
B = Ultimate member’s distributive
share of the qualified conservation
contribution.
K = Upper-tier partnership’s allocated
portion of the qualified conserva-
tion contribution.
Proposed §1.170A-14(m)(4)(iii) pro-
vided that, after completion of these com-
putations, the contributing partnership
must determine the portion of the amount
determined under item G with respect to
each ultimate member that is allocable
to the portion of the real property with
respect to which the qualified conserva-
tion contribution is made. This determina-
tion must be done in accordance with the
principles of §1.170A-14(m)(2), and the
following formula:
R = G × (V ÷ (L + V))
Where:
R = Relevant basis.
G = Amount determined with respect
to item G as described under
§1.170A-14(m)(4)(ii)(B).
L = Upper-tier partnership’s portion
of adjusted basis in all the con-
tributing partnership’s properties
(other than the portion of the real
property with respect to which
the qualified conservation contri-
bution is made), determined by
apportioning among the partners
of the contributing partnership
in accordance with their inter-
ests in the partnership under sec-
tion 704(b) its adjusted basis in
each of its properties (except the
interest in the contributing part-
nership), using the adjusted bases
immediately before the qualified
conservation contribution, with-
out duplication or omission of
any property, and by treating the
adjusted basis in each property as
not less than zero.
V = Upper-tier partnership’s share
of the contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made, determined
according to the following for-
mula: A × (K ÷ C).
A = Contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made.
K = Upper-tier partnership’s allocated
portion of the qualified conserva-
tion contribution.
C = Total amount of the contributing
partnership’s qualified conserva-
tion contribution.
a. Complexity of the determination of
relevant basis for ultimate members that
are partners in an upper-tier partnership
Several commenters criticized the
complexity of the proposed regulations’
method for determining relevant basis in
tiered entity arrangements. For example,
one commenter stated that the proposed
regulations use “difficult multivariable
mathematical formulae” like G = M × (U
÷ (J + U)) and R = G × (V ÷ (L + V)). The
commenter stated that these calculations
“are appropriate for launching rockets
or building bridges, but not for claiming
Congressionally-encouraged tax incen-
tives for land conservation.” Another
commenter stated that the complexity of
the proposed regulations places a signifi-
cant burden on the IRS and the Indepen-
dent Office of Appeals to determine com-
pliance at the level of an “indeterminable
number” of upper-tier partnerships. The
commenter stated that the proposed reg-
ulations provide an “unclear legal stan-
dard with respect to the application of the
Disallowance Rule to tiered partnership
structures and thus do not promote sim-
plification and taxpayer burden reduc-
tion.”
Another commenter stated that, of
the conservation easement contributions
made by partnerships, very few are made
by tiered partnerships. The commenter
stated that, after enactment of the Disal-
lowance Rule, there will be even fewer,
noting that many of those structures were

Bulletin No. 2024–30 83 July 22, 2024
created to facilitate transactions that are
now banned.
The Treasury Department and the IRS
have determined that the proposed compu-
tations are not more complex than neces-
sary to effectuate the Disallowance Rule.
In the context of tiered entities, section
170(h)(7)(A) requires the Disallowance
Rule to be tested at each tier and requires
relevant basis to be determined by look-
ing through all tiers of pass-through enti-
ties to determine the portion of modified
basis that is attributable to the portion of
the real property with respect to which
the qualified conservation contribution is
made. For example, if an individual is a
partner in an upper-tier partnership, and a
lower-tier partnership makes a qualified
conservation contribution, section 170(h)
(7)(A) requires each partnership to deter-
mine if the amount of the contribution
exceeds 2.5 times the sum of the relevant
bases. Section 170(h)(7)(B)(i) provides
that the individual’s relevant basis is the
portion of the individual’s modified basis
in the upper-tier partnership that is allo-
cable (under rules similar to the rules
of section 755) to the portion of the real
property held by the lower-tier partnership
with respect to which the qualified conser-
vation contribution is made.
Applying the rules of section 755 to
tiered entities involves computations at
each tier, which can be complex. Reve-
nue Ruling 87-115, 1987-2 C.B. 163, Sit-
uation 1, describes the sale of an interest
in an upper-tier partnership that holds an
interest in a lower-tier partnership. The
upper-tier partnership and the lower-tier
partnership both have elections in effect
under section 754 of the Code. Rev. Rul.
87-115 concludes that, in addition to the
upper-tier partnership computing section
743(b) adjustments and allocating them
among its properties under section 755,
an interest in the lower-tier partnership
will be deemed to have been transferred
for purposes of the lower-tier partnership
computing section 743(b) adjustments and
allocating them among the lower-tier part-
nership’s properties under section 755.
Thus, the rules of section 755 will have to
be applied at each tier. Similarly, Revenue
Ruling 92-15, 1992-1 C.B. 215, Situation
1, provides that if an upper-tier partnership
makes an adjustment under section 734(b)
that is allocated under the rules of section
755 to the basis of an interest it holds in a
lower-tier partnership that has an election
under section 754 in effect, the lower-tier
partnership must make section 734(b)
adjustments to the upper-tier partnership’s
share of the lower-tier partnership’s assets
and allocate those adjustments among the
lower-tier partnership’s property under
the rules of section 755. Thus, the rules of
section 755 will have to be applied at each
tier to determine the allocation of the sec-
tion 734(b) adjustments.
As explained earlier, the proposed
regulations are similar to, and not more
complex than, the rules of section 755.
In addition, the proposed regulations are
more consistent with the purposes of the
Disallowance Rule than a rule that sim-
ply cross-references section 755. Both of
these statements are also true with respect
to tiered partnership arrangements. The
computational step-by-step approach in
the proposed regulations provides a clear,
administrable standard, and protects the
purposes of the Disallowance Rule in situ-
ations involving tiered partnerships.
The Treasury Department and the IRS
disagree with the commenter who stated
that the proposed regulations apply to an
“indeterminate” number of tiers. The num-
ber of tiers is determinable, and within the
control of the taxpayers creating those
tiers. The proposed regulations provide
a flexible approach to accommodate any
number of tiers created by taxpayers.
This flexibility is necessary to prevent the
avoidance of the purposes of the Disal-
lowance Rule. If the regulations stopped
at two tiers, taxpayers could create struc-
tures with additional tiers and assert that
they are not required to properly trace rel-
evant basis through all the tiers. In addi-
tion, one commenter reported that many
tiered partnership arrangements were cre-
ated to engage in the very types of abusive
transactions which led Congress to enact
the Disallowance Rule. Accordingly, these
final regulations do not make changes in
response to the comments regarding the
complexity of the relevant basis computa-
tions in tiered partnership situations.
b. Effect of section 704(c) on the
allocation of modified basis
As discussed in Part II.B.1.b of this
Summary of Comments and Explana-
tion of Revisions, these final regulations
amend §1.170A-14(m)(2)(iii)(B) and
item D in the formula in §1.170A-14(m)
(2)(iv), which address the apportionment
of a contributing partnership’s adjusted
bases in its properties. To provide a par-
allel rule for an upper-tier partnership’s
apportionment of its adjusted bases in
its properties, §1.170A-14(m)(4)(ii)(A)
(2) in these final regulations provides
that to determine a partner’s portion of
the adjusted basis in all of an upper-tier
partnership’s properties, the upper-tier
partnership must apportion among its
partners its adjusted basis in each of its
properties (except its interest in the low-
er-tier partnership), using the adjusted
basis immediately before the quali-
fied conservation contribution, without
duplication or omission of any prop-
erty, and by treating the adjusted basis
in each property as not less than zero.
This apportionment must be done under
principles similar to the determination
of the partners’ interests in the partner-
ship under section 704(b), including the
factors in §1.704-1(b)(3)(ii). In addition,
the apportionment must reflect section
704(c) principles. For example, if a part-
nership property has built-in loss (the
adjusted basis of the property exceeds
its fair market value), and section 704(c)
would require all of that built-in loss to
be allocated to a certain partner if that
property was sold, all of the basis in the
property that exceeds the property’s fair
market value must be apportioned to the
partner to whom the loss would be allo-
cated if the property was sold.
To effectuate this change, these final
regulations modify the definition of item J
in §1.170A-14(m)(4)(ii)(B) to be:
J = Ultimate member’s portion of the
adjusted basis in all the upper-tier part-
nership’s properties (other than the upper-
tier partnership’s interest in the contrib-
uting partnership) as determined under
§1.170A-14(m)(4)(ii)(A)(2).
To be consistent with the changes to
§1.170A-14(m)(2)(iii)(B), these final reg-
ulations modify the definition of item L in
§1.170A-14(m)(4)(ii)(B) to be:
L = Upper-tier partnership’s portion
of adjusted basis in all the contributing
partnership’s properties (other than the
portion of the real property with respect
to which the qualified conservation con-

July 22, 2024 84 Bulletin No. 2024–30
tribution is made) as determined under
§1.170A-14(m)(2)(iii)(B).
4. Determination of Relevant Basis
for Shareholders in Upper-Tier
S Corporations
Proposed §1.170A-14(m)(5) provided
rules for determining relevant basis for an
ultimate member holding a direct interest
in an upper-tier S corporation. Proposed
§1.170A-14(m)(5)(i) provided that the
ultimate member’s modified basis must
be traced through the upper-tier S corpo-
ration and any upper-tier partnerships to
the contributing partnership, and the con-
tributing partnership must determine the
relevant basis. This involves a multi-step
process under which, beginning with the
upper-tier S corporation, the upper-tier
S corporation and any upper-tier partner-
ships would be required to perform cal-
culations, and then finally the contribut-
ing partnership would be required to use
those calculations to compute the ultimate
member’s relevant basis.
Proposed §1.170A-14(m)(5)(ii)(A)
provided a narrative rule for the upper-
tier S corporation. Under proposed
§1.170A-14(m)(5)(ii)(A), the upper-tier
S corporation must determine the portion
of each ultimate member’s modified basis
that is allocable to the upper-tier S corpo-
ration’s interest in the partnership in which
it holds a direct interest (in a situation
involving only two tiers, that will be the
contributing partnership). This determina-
tion must be done in accordance with the
principles of §1.170A-14(m)(3) and the
formula provided in §1.170A-14(m)(5)(ii)
(B). In other words, the formula provided
in §1.170A-14(m)(5)(ii)(B) is similar to
the formula provided in §1.170A-14(m)
(3), except that, instead of determining the
portion of modified basis that is allocable
to the portion of the real property with
respect to which the qualified conserva-
tion contribution is made, the formula in
§1.170A-14(m)(5)(ii)(B) determines the
portion of modified basis that is allocable
to the upper-tier S corporation’s inter-
est in the next lower-tier partnership. As
explained in §1.170A-14(m)(5)(iii), the
contributing partnership will then use the
amount determined under the formula in
§1.170A-14(m)(5)(ii)(B) to compute the
portion of modified basis that is allocable
to the portion of the real property with
respect to which the qualified conserva-
tion contribution is made.
Proposed §1.170A-14(m)(5)(ii)(B)
provided the following formula:
N = M × (P ÷ Q)
Where:
N = Portion of the ultimate member’s
modified basis that is allocable
to the upper-tier S corporation’s
interest in the contributing part-
nership.
M = Modified basis as determined
under §1.170A-14(l).
P = Ultimate member’s pro rata por-
tion of the upper-tier S corpora-
tion’s adjusted basis in its interest
in the contributing partnership.
Q = Ultimate member’s pro rata por-
tion of the adjusted basis in all the
upper-tier S corporation’s prop-
erties (including the upper-tier S
corporation’s adjusted basis in its
interest in the contributing part-
nership).
Proposed §1.170A-14(m)(5)(iii) pro-
vided that, after completion of these com-
putations, the contributing partnership
must determine the portion of the amount
determined under item N with respect to
each ultimate member that is allocable
to the portion of the real property with
respect to which the qualified conserva-
tion contribution is made. This determina-
tion must be done in accordance with the
principles of §1.170A-14(m)(2), and the
following formula:
R = N × (W ÷ (S + W))
Where:
R = Relevant basis.
N = Amount determined with respect
to item N as described under
§1.170A-14(m)(5)(ii)(B).
S = Upper-tier S corporation’s por-
tion of the adjusted basis in all
the contributing partnership’s
properties (other than the portion
of the real property with respect
to which the qualified conserva-
tion contribution is made), deter-
mined by apportioning among the
partners of the contributing part-
nership in accordance with their
interests in the partnership under
section 704(b) its adjusted basis in
each of its properties (other than
the portion of the real property
with respect to which the quali-
fied conservation contribution is
made), using the adjusted bases
immediately before the qualified
conservation contribution, with-
out duplication or omission of
any property, and by treating the
adjusted basis in each property as
not less than zero.
W = Upper-tier S corporation’s share
of the contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made, determined
according to the following for-
mula: A × (Y ÷ C).
A = Contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made.
Y = Upper-tier S corporation’s allo-
cated portion of the qualified con-
servation contribution.
C = Total amount of the contributing
partnership’s qualified conserva-
tion contribution.
a. Complexity of the determination of
relevant basis for ultimate members
that are shareholders in an upper-tier
S corporation
Commenters did not provide comments
specific to S corporations, but an upper-
tier S corporation would necessarily hold
an interest in a partnership, so the rules
applicable to partnerships would apply
to any partnership owned by the S corpo-
ration. For the reasons described in Part
II.B.3.a of this Summary of Comments
and Explanation of Revisions (relating
to the complexity of the determination of
relevant basis for ultimate members that
are partners in an upper-tier partnership),
the Treasury Department and the IRS have
determined that these computations should
be retained. Accordingly, these final regu-
lations do not make changes in response
to the comments regarding the complexity
of the relevant basis computations in situ-

Bulletin No. 2024–30 85 July 22, 2024
ations involving an S corporation owning
an interest in a lower-tier partnership.
b. Effect of section 704(c) on the
allocation of modified basis
As discussed in Part II.B.1.b of this
Summary of Comments and Explana-
tion of Revisions, these final regulations
amend §1.170A-14(m)(2)(iii)(B) and item
D in the formula in §1.170A-14(m)(2)
(iv). To be consistent with those revisions,
these final regulations modify the defini-
tion of item S in §1.170A-14(m)(5)(iii)(B)
to be:
S = Upper-tier S corporation’s portion
of the adjusted basis in all the contribut-
ing partnership’s properties (other than the
portion of the real property with respect
to which the qualified conservation con-
tribution is made) as determined under
§1.170A-14(m)(2)(iii)(B).
III. Requests for Guidance on
Partnership Allocations
Subchapter K and the regulations
thereunder provide rules on how a part-
nership may allocate its items among its
partners. Several commenters requested
that the final regulations provide guid-
ance on partnership allocations of qual-
ified conservation contributions. These
comments are grouped into the follow-
ing categories: (A) requests for guidance
under section 704(b), (B) requests for
guidance under section 704(c), and (C)
requests for additional guidance on the
application of the proposed regulations
under §1.706-3.
A. Requests for guidance under section
704(b)
Section 704(b) provides that a part-
ner’s distributive share of income, gain,
loss, deduction, or credit is determined in
accordance with the partner’s interest in
the partnership if the partnership agree-
ment does not provide as to the partner’s
distributive share of these items or the
allocation to a partner of these items under
the agreement does not have substantial
economic effect. The existing regulations
under section 704(b) provide guidance,
including definitions of substantial eco-
nomic effect, capital account provisions,
and guidance on the determination of a
partner’s interest in the partnership.
The proposed regulations did not
address section 704(b) allocation issues.
The examples in the proposed regulations
tell the reader to assume that the partner-
ship allocations comply with the rules
of subchapter K. Commenters requested
guidance on the following issues involv-
ing section 704(b): (1) allocations of qual-
ified conservation contributions under
section 704(b), and (2) section 704(b) cap-
ital accounting for qualified conservation
contributions.
1. Allocations of Qualified Conservation
Contributions under Section 704(b)
One commenter stated that the pro-
posed regulations suggest that a partner-
ship can allocate qualified conservation
contributions in any manner it chooses
irrespective of the rules under subchapter
K. The commenter stated that a partner-
ship’s allocation of a qualified conserva-
tion contribution must reflect either the
partners’ interests in the partnership or
qualify as a special allocation that satisfies
the substantial economic effect rules. The
commenter recommended that the final
regulations qualify any suggestion that
special allocations may be used in allocat-
ing qualified conservation contributions.
Without that, the commenter stated that
the examples in the proposed regulations
may be taken as permission from the
IRS to create a new situation in which an
investor receives more than 2.5 times its
basis in tax deductions.
The proposed regulations do not sug-
gest that a partnership’s allocation of a
qualified conservation contribution is
not subject to the rules of subchapter K.
As noted, the examples in the proposed
regulations tell the reader to assume that
the partnership allocations comply with
the rules of subchapter K. The focus of
these regulations is the implementation of
section 170(f)(19) and (h)(7), which gen-
erally do not change the rules for how a
partnership may allocate a qualified con-
servation contribution among its partners
under section 704(b). Accordingly, guid-
ance on the application of section 704(b)
to a partnership’s allocations of qualified
conservation contributions is outside the
scope of these regulations.
The Treasury Department and the IRS
note that the Disallowance Rule does not
prevent all situations in which an inves-
tor receives more than 2.5 times its basis
in tax-deductible qualified conservation
contributions. See §1.170A-14(j)(6)(ii)
(Example 2) for a situation in which the
amount of a partnership’s qualified con-
servation contribution does not exceed
2.5 times the sum of the partners’ relevant
bases, even though one partner’s share of
the contribution exceeds 2.5 times that
partner’s relevant basis. Such transactions
may, however, constitute a listed transac-
tion.
2. Section 704(b) Capital Accounting for
Qualified Conservation Contributions
Regulations under section 704(b) pro-
vide rules for maintenance of a partner’s
capital account. In general terms, a part-
ner’s capital account is increased by the
amount of money the partner contributes
to the partnership, the fair market value
of property the partner contributes to the
partnership, and allocations to the part-
ner of partnership income and gain. In
general terms, a partner’s capital account
is decreased by the amount of money
distributed to the partner by the partner-
ship, the fair market value of any property
distributed to the partner, allocations of
section 705(a)(2)(B) expenditures of the
partnership, and allocations of partner-
ship loss and deduction. See §1.704-1(b)
(2)(iv). Section 705(a)(2)(B) expenditures
are expenditures of a partnership that are
not deductible in computing its taxable
income and not properly chargeable to its
capital accounts. Revenue Ruling 96-11,
1996-1 C.B. 140, provides that a noncash
charitable contribution by a partnership is
a section 705(a)(2)(B) expenditure.
Two commenters requested guidance
on how a disallowed qualified conser-
vation contribution would affect capital
accounts. They stated that the proposed
regulations provide rules for determining
whether a qualified conservation contri-
bution runs afoul of section 170(h)(7) but
fail to provide capital accounting guidance
under section 704(b) to the extent that
a contribution is disallowed. One com-
menter stated that, under the current sec-
tion 704(b) regulations, it is unclear what
impact a disallowed qualified conservation

July 22, 2024 86 Bulletin No. 2024–30
contribution would have on book capital
accounts. Another commenter stated that,
in the event that a contributing partnership
continues to conduct business follow-
ing a disallowed qualified conservation
contribution, the lack of section 704(b)
guidance will create confusion among
tax practitioners, increase the reporting
burden on taxpayers, and require further
guidance from the Treasury Department
and the IRS. These two commenters rec-
ommend that the final regulations include
book capital account guidance under sec-
tion 704(b) with respect to the Disallow-
ance Rule.
The Treasury Department and the IRS
have concluded that guidance on capital
account maintenance under section 704(b)
is outside the scope of these regulations.
There are several situations in which the
Code limits or disallows a deduction for
a partnership’s charitable contribution,
including other provisions of section 170.
As a result of these long-standing rules,
a partnership’s allowed charitable con-
tribution may be less than the fair mar-
ket value of the donated property. The
Disallowance Rule simply adds another
situation in which a deduction for a part-
nership’s charitable contribution will be
disallowed. Thus, this issue is broader
than contributions subject to the Disal-
lowance Rule. Accordingly, these final
regulations do not address partnership
capital accounting.
B. Requests for guidance under section
704(c)
In part, section 704(c) provides rules
for partnership allocations with respect to
property that had built-in gain or built-in
loss at the time the property was contrib-
uted by a partner to the partnership. Two
commenters sought guidance on whether:
(1) section 704(c)(1)(A) applies to qual-
ified conservation contributions, and (2)
section 704(c)(1)(B) applies to qualified
conservation contributions.
1. Application of Section 704(c)(1)(A) to
Charitable Contributions
Two commenters requested guidance
on whether section 704(c)(1)(A) applies
to the definition of distributive share in
the context of proposed §1.170A-14. The
commenters stated that the proposed reg-
ulations do not define the term “distribu-
tive share.” The commenters stated that,
as a result, it is unclear whether section
704(c) may apply to determine each part-
ner’s distributive share of a qualified con-
servation contribution. One commenter
stated that, to promote transparency, the
final regulations should define the term
“distributive share” and further discuss
what impact, if any, section 704(c) may
have with respect to conservation ease-
ment transactions in the context of sec-
tion 170(h).
Another commenter stated that none
of the examples in the proposed regu-
lations involve a qualified conservation
contribution with respect to property that
had been contributed to the partnership
by a partner, and that the application of
section 704(c) to allocations of charita-
ble contributions should be addressed.
The commenter hypothesized that the
proposed regulations will create an infer-
ence that the rules of section 704(c) do
not apply in the context of a contributed
property that is later the subject of a char-
itable contribution because it is unclear
under the existing section 704(c) regula-
tions whether charitable contributions of
contributed property are subject to sec-
tion 704(c). The commenter also attached
or referenced several articles addressing
whether Congress intended for section
704(c) to apply to charitable contribu-
tions.
The focus of these regulations is
implementation of section 170(f)(19) and
(h)(7). Thus, the application of section
704(c)(1)(A) to charitable contributions
by a partnership is outside the scope of
these regulations. However, the Treasury
Department and the IRS will continue to
study the issue.
2. Application of Section 704(c)(1)(B) to
Charitable Contributions
Section 704(c)(1)(B) provides in part
that, if a partner contributes property with
built-in gain or built-in loss to a partner-
ship, and the partnership distributes the
property (directly or indirectly) to some-
one other than the contributing partner
within seven years of the partner’s contri-
bution, the contributing partner is treated
as recognizing gain or loss (as the case
may be) from the sale of such property in
an amount equal to the gain or loss which
would have been allocated to such partner
under section 704(c)(1)(A) if the property
had been sold at its fair market value at the
time of the distribution.
One commenter requested guidance
on whether section 704(c)(1)(B) would
apply if a partner contributes real prop-
erty to a partnership and within seven
years the partnership makes a qualified
conservation contribution with respect to
that property. The commenter stated that
a partnership’s charitable contribution is
substantively equivalent to a partnership
distribution followed by a charitable con-
tribution by the partners.
The focus of these regulations is
implementation of section 170(f)(19) and
(h)(7). Thus, the application of section
704(c)(1)(B) to charitable contributions
by a partnership is outside the scope of
these regulations. However, the Treasury
Department and the IRS will continue to
study the issue.
C. Proposed regulations under §1.706-3
Section 706(d)(3) of the Code pro-
vides rules for an upper-tier partner-
ship’s allocation of items to its partners
attributable to an interest in a lower-tier
partnership. It provides that if, during
any taxable year of the upper-tier part-
nership, there is a change in any part-
ner’s interest in the upper-tier partner-
ship, then (except to the extent provided
in regulations) each partner’s distribu-
tive share of any item of the upper-tier
partnership attributable to the lower-tier
partnership must be determined by
assigning the appropriate portion (deter-
mined by applying principles similar to
the principles of section 706(d)(2)(C)
and (D)) of each such item to the appro-
priate days during which the upper-tier
partnership is a partner in the lower-tier
partnership and by allocating the por-
tion assigned to any such day among the
partners in proportion to their interests
in the upper-tier partnership at the close
of such day.
To facilitate the computation of a part-
ner’s relevant basis immediately before
the contribution, proposed §1.706-3(a)
provided that, for purposes of section
706(d)(3), in the case of a qualified con-

Bulletin No. 2024–30 87 July 22, 2024
servation contribution (without regard
to whether such contribution is a dis-
allowed qualified conservation contri-
bution within the meaning of proposed
§1.170A-14(j)(3)(vii)) by a partnership
that is allocated to an upper-tier part-
nership, the upper-tier partnership must
allocate the contribution among its part-
ners in proportion to their interests in
the upper-tier partnership at the time of
day at which the contribution was made,
regardless of the method (interim clos-
ing or proration) and convention (daily,
semi-monthly, or monthly) otherwise
used by the upper-tier partnership under
§1.706-4.
The following sections of this Sum-
mary of Comments and Explanation of
Revisions address two issues under pro-
posed §1.706-3(a): (1) whether proposed
§1.706-3(a) requires pro rata allocations,
and (2) whether proposed §1.706-3(a)
withdraws the 2015 proposed regulations
under §1.706-3.
1. Whether Proposed §1.706-3(a)
Requires Pro Rata Allocations
The Treasury Department and the
IRS understand that there are questions
whether the language in proposed §1.706-
3(a) stating that the upper-tier partnership
must allocate the qualified conservation
contribution among its partners “in pro-
portion to their interests in the upper-tier
partnership” requires the upper-tier part-
nership to allocate the contribution among
its partners pro rata, with no special allo-
cations.
The Treasury Department and the IRS
did not intend for proposed §1.706-3(a) to
require an upper-tier partnership to allo-
cate a qualified conservation contribution
pro rata among its partners. Accordingly,
the final regulations modify §1.706-3(a)
to provide that the upper-tier partnership
must allocate the contribution among its
partners in accordance with their interests
in the qualified conservation contribu-
tion at the time of day at which the qual-
ified conservation contribution was made,
rather than providing that the upper-tier
partnership must allocate the contribution
among its partners “in proportion to their
interests in the upper-tier partnership” at
the time of day at which the contribution
was made.
2. Whether Proposed §1.706-3(a) and (b)
Withdraw the 2015 Proposed Regulations
Under §1.706-3
One commenter asked about the effect
of the proposed regulations on proposed
regulations under §1.706-3 published
August 3, 2015, REG-109370-10 (80 FR
45905) (the 2015 proposed regulations).
The 2015 proposed regulations proposed
guidance under the general rule of section
706(d)(3).
The proposed regulations did not with-
draw, nor did they intend to withdraw, the
2015 proposed regulations. Instead, the
proposed regulations under §1.706-3 are
a regulatory exception to the general rule
in section 706(d)(3), to which the 2015
proposed regulations relate. To avoid con-
fusion, these regulations renumber the
guidance under §1.706-3 to follow the
numbering in the 2015 proposed regula-
tions. Thus, proposed §1.706-3(a) and (b)
are finalized as §1.706-3(d) and (e), incor-
porating the changes described in this sec-
tion of the preamble. Section 1.706-3(a)
through (c) are reserved for the 2015 pro-
posed regulations.
In addition, the Treasury Department
and the IRS have determined that the lan-
guage in proposed §1.706-3 might cause
confusion because it states that the upper-
tier partnership must allocate the qualified
conservation contribution as described
in §1.706-3 regardless of the method
(interim closing or proration) and con-
vention (daily, semi-monthly, or monthly)
otherwise used by the upper-tier partner-
ship under §1.706-4. This reference to
§1.706-4 might cause confusion because
§1.706-4(a)(2) provides in part that items
subject to allocation under section 706(d)
(3) are not subject to the rules of §1.706-
4. Thus, although proposed §1.706-3 is
correct to state that the upper-tier partner-
ship’s allocation of the qualified conser-
vation contribution must be done without
regard to the rules of §1.706-4, the ref-
erence to §1.706-4 may be read to imply
that the rules of §1.706-4 would otherwise
apply to an upper-tier partnership’s allo-
cation of items attributable to a lower-tier
partnership.
To avoid confusion, these final regula-
tions modify proposed §1.706-3(a) to pro-
vide that, for purposes of section 706(d)
(3), in the case of a qualified conservation
contribution (as defined in section 170(h)
(1) and §1.170A-14(a) without regard to
whether such contribution is a disallowed
qualified conservation contribution within
the meaning of §1.170A-14(j)(3)(vii)) by
a partnership that is allocated to an upper-
tier partnership, the upper-tier partnership
must allocate the contribution among its
partners in accordance with their interests
in the qualified conservation contribu-
tion at the time of day at which the qual-
ified conservation contribution was made,
regardless of the general rule of section
706(d)(3). The final regulations provide
that, pursuant to §1.706-4(a)(2), the rules
of §1.706-4 do not apply to allocations
subject to §1.706-3.
IV. Exceptions to the Disallowance Rule
Section 170(h)(7) contains three
exceptions to the Disallowance Rule: the
three-year holding period exception, the
family pass-through entity exception,
and the certified historic structure excep-
tion. The proposed regulations included
each exception and provided additional
guidance. Commenters addressed each of
these exceptions, requested an exception
for de minimis overages, and requested a
more explicit statement of the taxpayers
to whom the Disallowance Rule does not
apply. Each category of comments is dis-
cussed in turn in the following sections of
this preamble.
A. Exception for contributions outside
three-year holding period
Section 170(h)(7)(C) provides that
the Disallowance Rule does not apply
to any contribution made at least three
years after the latest of: (1) the last date
on which the pass-through entity that
made such contribution acquired any por-
tion of the real property with respect to
which such contribution is made, (2) the
last date on which any owner of the pass-
through entity that made such contribution
acquired any interest in such pass-through
entity, and (3) if the interest in the pass-
through entity that made such contribution
is held through one or more pass-through
entities, the last date on which any such
pass-through entity acquired any inter-
est in any other such pass-through entity,
and the last date on which any owner in

July 22, 2024 88 Bulletin No. 2024–30
any such pass-through entity acquired
any interest in such pass-through entity.
4

Neither section 605 of the SECURE 2.0
Act nor section 170 defines the phrase
“acquired any interest.”
Proposed §1.170A-14(n)(2)(ii) and (iii)
defined the phrase “acquired any inter-
est” for partnerships and S corporations,
respectively. Proposed §1.170A-14(n)(2)
(iv) also clarified that, if the contributing
partnership or contributing S corporation
does not satisfy the requirements of pro-
posed §1.170A-14(n)(2), then proposed
§1.170A-14(n)(2) would not apply to any
person who receives a distributive share
or pro rata share of the qualified conserva-
tion contribution (including an upper-tier
partnership or upper-tier S corporation),
regardless of whether the person receiving
such distributive share or pro rata share
would have satisfied the requirements of
proposed §1.170A-14(n)(2) if the person
had been the one to make the qualified
conservation contribution. The proposed
regulations contained two examples illus-
trating these rules. The preamble to the
proposed regulations requested comments
on whether any additional rules or exam-
ples should be provided for the three-year
holding period exception.
The only comment received on pro-
posed §1.170A-14(n)(2) supported the
three-year holding period exception and
stated that no further guidance is needed
on the topic. Accordingly, these regula-
tions finalize the proposed regulations
under §1.170A-14(n)(2) without change.
B. Exception for family pass-through
entities
Section 170(h)(7)(D)(i) provides that
the Disallowance Rule does not apply
to any contribution made by any pass-
through entity if substantially all of the
interests in such pass-through entity are
held, directly or indirectly, by an individ-
ual and members of the family of such
individual. Section 170(h)(7)(D)(ii) pro-
vides that, for purposes of section 170(h)
(7)(D), the term “members of the family”
means, with respect to any individual:
(1) the spouse of such individual, and
(2) any individual who bears a relation-
ship to such individual that is described
in section 152(d)(2)(A) through (G) of the
Code for purposes of determining whether
an individual is a qualifying relative.
Proposed §1.170A-14(n)(3) provided
guidance under the family pass-through
entity exception for partnerships and S
corporations, including: (1) defining “sub-
stantially all of the interests,” (2) pro-
viding that “members of the family” are
limited to individuals, and (3) imposing
two anti-abuse rules for the family pass-
through entity exception.
In addition, proposed §1.170A-14(n)
(3)(v) provided that, if the contributing
partnership or contributing S corporation
does not satisfy the requirements of pro-
posed §1.170A-14(n)(3), then the excep-
tion in proposed §1.170A-14(n)(3) would
not apply to any person who receives
a distributive share or pro rata share of
the qualified conservation contribution
(including an upper-tier partnership or
upper-tier S corporation), regardless of
whether the person receiving such distrib-
utive share or pro rata share would have
satisfied the requirements of proposed
§1.170A-14(n)(3) if the person had been
the one to make the contribution. No com-
ments were received on the rule in pro-
posed §1.170A-14(n)(3)(v). Accordingly,
the rule in proposed §1.170A-14(n)(3)(v)
is finalized without change.
One commenter expressed support
for the family pass-through entity excep-
tion and stated that further guidance was
not needed. Other commenters requested
modifications on: (1) the definition of
“substantially all of the interests,” (2) the
limitation of “members of the family” to
individuals, and (3) the two anti-abuse
rules for the family pass-through entity
exception.
1. Defining “Substantially All of the
Interests”
Section 170(h)(7) does not contain
a definition of “substantially all.” The
preamble to the proposed regulations
mentioned that, for purposes of applying
different provisions of the Code that also
use that term, various Income Tax Regula-
tions define the term “substantially all” as
comprising different percentages, includ-
ing: 70 percent (§1.1400Z2(d)-2(d)(4));
80 percent (§§1.41-2(d)(2), 1.41-4(a)(6));
85 percent (§§1.45D-1(c)(5), 1.72(e)-1T,
Q&A 3, 1.528-4(b) and (c)); 90 percent
(§§1.103-8(a)(1)(i), 1.103-16(c), 1.731-
2(c)(3)(i), 1.1400Z2(d)-2(d)(3)); and 95
percent (§§1.448-1T(e)(4)(i) and (e)(5)(i),
1.460-6(d)(4)(i)(D)(1)).
The preamble to the proposed regula-
tions stated that it is appropriate to select a
percentage at the higher end of this range to
carry out the purpose of the Disallowance
Rule, which is to prevent abusive syndi-
cations of qualified conservation contribu-
tions. Thus, proposed §1.170A-14(n)(3)
(i) provided that the family pass-through
entity exception applied if at least ninety
percent of the interests in the contributing
partnership or contributing S corporation
are held by an individual and members
of the family of such individual and the
contributing partnership or contributing
S corporation meets the requirements of
proposed §1.170A-14(n)(3).
Proposed §1.170A-14(n)(3)(ii)(A) pro-
vided that, in the case of a contributing
partnership, at least ninety percent of the
interests in the contributing partnership
are held by an individual and members of
the family of such individual if, at the time
of the qualified conservation contribution,
at least ninety percent of the interests in
capital and profits in such partnership are
held, directly or indirectly, by an individ-
ual and members of the family of such
individual. Proposed §1.170A-14(n)(3)(ii)
(B) provided that, in the case of a contrib-
uting S corporation, at least ninety percent
of the interests in the contributing S cor-
poration are held by an individual and
members of the family of such individual
if, at the time of the qualified conservation
contribution, at least ninety percent of the
total value and at least ninety percent of
the total voting power of the outstanding
stock in such S corporation are held by an
individual and members of the family of
such individual.
One commenter agreed that ninety per-
cent was a reasonable number to define
4
The Treasury Department and the IRS note that section 170(h)(7)(C) and §1.170A-14(n)(2) are based upon dates of acquisition, not “holding periods,” and therefore, although this exception
is colloquially referred to as the “three-year holding period exception,” the tacked holding period rules of section 1223 of the Code do not apply in determining the application of section
170(h)(7)(C) and §1.170A-14(n)(2).

Bulletin No. 2024–30 89 July 22, 2024
substantially all, noting that interests held
by persons who are not members of the
family should be “extremely limited.”
Another commenter stated that ninety per-
cent was too high and would unnecessarily
restrict the application of the family pass-
through entity exception; however, that
commenter did not provide any examples
of unnecessary restrictions or recommend
a different percentage. A third commenter
recommended lowering the percentage
to eighty-five percent, citing the eighty-
five percent standard in Rev. Rul. 73-248,
1973-1 C.B. 295, and the fact that this
Revenue Ruling relates to the percentage
of ownership in a legal entity, as opposed
to the percentage of cash, percentage of
assets, or percentage of time. This com-
menter also noted that eighty-five percent
was closest to the average of the various
percentages used to define “substantially
all” discussed in the preamble to the pro-
posed regulations.
The Treasury Department and the IRS
agree with the commenter stating that inter-
ests held by persons who are not members
of the family should be extremely limited
and that ninety percent is a reasonable
number to define “substantially all.” In the
view of the Treasury Department and the
IRS, the intent of not requiring one-hun-
dred percent of a contributing entity to be
owned by family members was to allow
non-family members to make small,
non-material investments in contributing
entities, such as when a family partnership
issues profits interests to service provid-
ers. The two commenters who stated that
ninety percent is too high did not elaborate
or give examples in which a family part-
nership or family S corporation needed to
provide more than ten percent of its inter-
ests to persons who are not members of
the family but still should meet the family
pass-through entity exception to the Disal-
lowance Rule. Further, the average of per-
centages used to define “substantially all”
in guidance is not relevant to the definition
that makes sense in the context of section
170(h)(7). Thus, these final regulations
adopt the definition of “substantially all”
as proposed.
2. Defining “Members of the Family”
Consistent with section 170(h)(7)(D)
(ii), proposed §1.170A-14(n)(3)(iii) pro-
vided that, for purposes of §1.170A-14(n)
(3), the term “members of the family”
means, with respect to any individual:
(1) the spouse of such individual, and
(2) any individual who bears a relation-
ship to such individual that is described
in section 152(d)(2)(A) through (G). The
preamble to the proposed regulations
stated that, under this rule, members of
the family would be limited to individu-
als and requested comments on whether
certain estates or trusts should be treated
as members of the family for purposes of
the family pass-through entity exception.
The preamble also noted that, under exist-
ing §1.1361-1(e)(3)(ii), certain estates and
trusts of deceased members of the family
are treated as members of the family for
purposes of the limitation on the number
of shareholders in an S corporation.
One commenter requested that estates
and trusts of deceased individuals be
included in the definition of “members
of the family” to address the fact that the
interests of deceased individuals may be
included in conservation contributions.
In the view of the Treasury Department
and the IRS, if a family member dies and
the member’s interest in the pass-through
entity has been transferred to the dece-
dent’s estate, the interest still should be
considered to be held by a member of the
family. Otherwise, the pass-through entity
might have to wait until final disposition
of the estate (which may take years) to
make a deductible qualified conservation
contribution, even if the beneficiaries of
the estate are all themselves individual
members of the family. In addition, allow-
ing a decedent’s estate to be treated as a
member of the family if the decedent was
a member of the family at the time of death
is administrable because determining
whether the estate qualified as a member
of the family involves the same determi-
nation as whether the decedent qualified
as a member of the family before death.
Accordingly, these final regulations mod-
ify §1.170A-14(n)(3)(iii) to provide that a
decedent’s estate is treated as a member of
the family for purposes of §1.170A-14(n)
(3) if the decedent was a member of the
family at the time of death.
In addition, as noted by the commenter,
certain trusts may raise similar issues.
Trusts may be partners or S corporation
shareholders, or may become partners or
shareholders as a result of the death of
an individual member of the family. For
example, if a family member holds a part-
nership interest through a grantor trust,
that individual would meet the require-
ments under these regulations of holding
a direct interest in the partnership under
§1.170A-14(j)(3)(v). If that family mem-
ber dies and the trust is no longer a grantor
trust, the trust should not automatically
cause the partnership to no longer be a
family partnership. If only family mem-
bers are potential beneficiaries of a trust,
then the trust should be treated as being
a member of the family. Including such a
trust would serve the purpose of the statute
to maintain an exception for partnerships
and S corporations owned and controlled
by a family. A contributing partnership
or contributing S corporation that would
otherwise satisfy the requirements of
the family pass-through entity exception
should not be excluded from the exception
merely because interests are held through
a family trust. Accordingly, these final
regulations modify §1.170A-14(n)(3)(iii)
to provide that a trust, all of the beneficia-
ries of which are individuals described in
§1.170A-14(n)(3)(iii)(A) or (B), is treated
as a member of the family. For this pur-
pose, the term “beneficiaries” refers to
those persons who currently must or may
receive income or principal from the trust
and those persons who would succeed to
the property of the trust if the trust were
to terminate immediately before the quali-
fied conservation contribution.
3. Anti-Abuse Rules for the Family Pass-
Through Entity Exception
The Disallowance Rule and its excep-
tions in section 170(h)(7) are generally
mechanical. However, Congress recog-
nized that additional guidance may be
needed to prevent situations in which
those mechanical rules are used to avoid
the purposes of the Disallowance Rule.
Section 170(h)(7)(G)(ii) provides the Sec-
retary with authority to issue regulations
or other guidance to prevent the avoid-
ance of the purposes of section 170(h)
(7). Accordingly, to ensure that the family
pass-through entity exception in proposed
§1.170A-14(n)(3) would not be used inap-
propriately to circumvent the Disallow-
ance Rule, the proposed regulations con-

July 22, 2024 90 Bulletin No. 2024–30
tained two anti-abuse rules: (1) a one-year
holding period, and (2) a ninety-percent
allocation rule.
a. One-year holding period
Proposed §1.170A-14(n)(3)(iv)(A)
provided that the family pass-through
entity exception does not apply unless at
least ninety percent of the interests in the
property with respect to which the quali-
fied conservation contribution was made
were owned, directly or indirectly, by one
individual and members of the family of
that individual for at least one year prior
to the date of the contribution.
The preamble to the proposed regu-
lations explained that the need for such
a rule is the concern that, in the absence
of a requirement that the members of the
family hold the contributed property for
a certain period before the contribution,
promoters could structure transactions
to inappropriately take advantage of cer-
tain tacked-holding-period transactions
together with the family pass-through
entity exception. The proposed regulations
provided an example of such a situation, in
which a lower-tier partnership that is not a
family pass-through entity distributes its
real property to an S corporation and an
upper-tier partnership. The S corporation
and the upper-tier partnership each sep-
arately qualify as a family pass-through
entity, but the shareholders of the S corpo-
ration are not related to the partners of the
upper-tier partnership. Within one year of
the distribution, the S corporation makes
a qualified conservation contribution. The
example concludes that, even though at
the time of the qualified conservation con-
tribution the S corporation is completely
owned by an individual and members of
the family, the family pass-through entity
exception does not apply because the one-
year holding period requirement was not
met.
Two commenters disagreed with the
one-year holding period. These com-
menters claimed that the inclusion of a
three-year holding period under section
170(h)(7)(C) and the absence of a one-
year holding period under the family
pass-through entity exception evidenced
a congressional intent not to include a
one-year holding period for the fam-
ily pass-through entity exception under
section 170(h)(7)(D). One of these com-
menters opined that the proposed one-
year holding period requirement violated
due process by retroactively binding
taxpayers who had already made contri-
butions that did not satisfy the one-year
holding period. The other commenter
stated that the Treasury Department and
the IRS had offered no evidence in sup-
port of the statement in the preamble to
the proposed regulations that reliance on
a tacked holding period raises serious
concerns that the family pass-through
entity exception is being used inappro-
priately to circumvent the Disallowance
Rule.
The Treasury Department and the IRS
disagree that the Treasury Department and
the IRS lack authority to promulgate an
anti-abuse rule. Section 170(h)(7)(G) is
a specific grant of authority to the Secre-
tary to prescribe such regulations or other
guidance as may be necessary or appro-
priate to carry out the purposes of section
170(h)(7), including regulations or other
guidance to prevent the avoidance of the
purposes of section 170(h)(7). In addition,
section 7805(a) authorizes the Secretary to
prescribe all needful rules and regulations
for the enforcement of title 26, including
all rules and regulations as may be nec-
essary by reason of any alteration of law
in relation to internal revenue. As noted
above, section 7805(b)(2) permits regula-
tions issued within 18 months of Decem-
ber 29, 2022 (the date SECURE 2.0 Act
was enacted), to apply to contributions
after December 29, 2022. Section 7805(b)
(3) provides that the Secretary may pro-
vide that any regulation may take effect or
apply retroactively to prevent abuse. Sec-
tion 170(h)(7)(G) and section 7805(a), (b)
(2), and (b)(3) provide ample authority for
an anti-abuse rule applicable to contribu-
tions after December 29, 2022.
The holding period anti-abuse rule is
necessary to address the potential for tax-
payers to inappropriately take advantage
of certain tacked-holding-period transac-
tions to utilize the family pass-through
entity exception. In particular, the exam-
ple in the proposed regulations illustrates
inappropriate avoidance of the purposes
of the Disallowance Rule. As described,
the example shows a distribution from
a partnership that is not a family pass-
through entity to two separate upper-tier
entities, each of which is a family pass-
through entity, followed by a qualified
conservation contribution within one year
of the distribution. This situation should
not qualify for the family pass-through
entity exception because the distributing
partnership was not a family pass-through
entity. If such a situation qualified for the
family pass-through entity exception, then
partnerships that fail to qualify as family
pass-through entities could simply dis-
tribute land to upper-tier entities, each of
which would be a family pass-through
entity (such as single-member S corpo-
rations or partnerships wholly-owned by
spouses) and thus each upper-tier entity
could inappropriately avail itself of the
family pass-through entity exception.
Without an anti-abuse rule, similar inap-
propriate results could be obtained through
other tacked-holding-period transactions,
including contributions to family pass-
through entities by persons who are not
members of the family.
However, after consideration of the
comments, the Treasury Department
and the IRS have decided to finalize the
one-year holding period rule with two
changes. First, the final regulations clarify
that, solely for purposes of §1.170A-14(n)
(3)(iv)(A), section 1223(1) and (2) of the
Code do not apply in determining whether
at least ninety percent of the interests in
the property with respect to which the
qualified conservation contribution was
made were owned, directly or indirectly,
by one individual and members of the fam-
ily of that individual for at least one year
prior to the date of the contribution. This
clarification is only for purposes of the
anti-abuse rule in §1.170A-14(n)(3)(iv)
(A) and does not affect the holding period
of the property for any other purpose,
including section 170(e). The Treasury
Department and the IRS note that this rule
was already implicit in the proposed reg-
ulations; in fact, proposed §1.170A-14(n)
(3)(vi)(B) (Example 2) described a situa-
tion in which an S corporation failed the
one-year holding period requirement even
though it would have had a tacked holding
period under section 1223 that exceeded
one year.
Second, the final regulations provide
that the one-year holding period rule does
not apply if the entire amount of the qual-
ified conservation contribution is limited

Bulletin No. 2024–30 91 July 22, 2024
by section 170(e) to the contributing part-
nership’s or contributing S corporation’s
adjusted basis in the qualified conserva-
tion contribution. For example, if section
170(e) limits a qualified conservation con-
tribution to the contributing partnership’s
adjusted basis because the property with
respect to which the qualified conserva-
tion contribution is made was purchased
within one year of the qualified conser-
vation contribution, the anti-abuse rule in
§1.170A-14(n)(3)(iv)(A) does not apply.
This change limits the one-year holding
requirement to transactions that inappro-
priately take advantage of tacked holding
periods to utilize the family pass-through
entity exception.
b. Ninety percent allocation rule
Proposed §1.170A-14(n)(3)(iv)(B)
provided that the exception in proposed
§1.170A-14(n)(3) does not apply unless at
least ninety percent of the qualified con-
servation contribution is allocated to the
individual and all members of the individ-
ual’s family who own at least ninety per-
cent of all the interests in the contributing
partnership or contributing S corporation.
Commenters did not comment on this
anti-abuse rule. Therefore, these regula-
tions maintain the ninety percent alloca-
tion rule.
C. Certified historic structure exception
Section 170(h)(7)(E) provides that the
Disallowance Rule does not apply to any
qualified conservation contribution the
conservation purpose of which is the pres-
ervation of any building that is a certified
historic structure (as defined in section
170(h)(4)(C)). Proposed §1.170A-14(n)
(4) simply repeated this statutory lan-
guage and did not provide further guid-
ance regarding the cases to which this
exception would apply. No comments
were received on proposed §1.170A-14(n)
(4), which these regulations finalize with-
out change.
Proposed §1.170A-14(n)(4) also
contained a cross-reference to the spe-
cial reporting requirements in proposed
§1.170A-16(f)(6) for a contribution that
meets the certified historic structure
exception. Several commenters addressed
these special reporting requirements.
Those comments are discussed in Part V.D
of this Summary of Comments and Expla-
nation of Revisions,
D. The request for a de minimis overage
exception
Section 170(h)(7)(A) states that a
contribution by a partnership (whether
directly or as a distributive share of a con-
tribution of another partnership) “shall
not be treated as” a qualified conserva-
tion contribution for purposes of section
170 if the amount of such contribution
exceeds 2.5 times the sum of each part-
ner’s relevant basis in such partnership.
One commenter stated that there is a “cliff
effect” to the statute and the proposed
regulations in that a contribution of one
dollar more than 2.5 times the sum of the
relevant bases results in disallowance of
any deduction for any of the contribution.
The commenter stated that there should be
some regulatory leniency if the taxpayer
was acting in good faith and there is de
minimis overage.
The Treasury Department and the IRS
agree with the commenter that the statu-
tory language imposes a “cliff effect,” but
do not agree that a de minimis exception
is necessary or desirable. As explained
in Part I of this Summary of Comments
and Explanation of Revisions, the first
sentence of proposed §1.170A-14(j)(3)
(ii), which these regulations finalize with-
out change, provides that the amount of a
contributing partnership’s or contributing
S corporation’s qualified conservation
contribution is the amount claimed as a
qualified conservation contribution on the
return of the contributing partnership or
contributing S corporation for the taxable
year in which the contribution is made.
By focusing on the amount claimed by
the contributing partnership or contrib-
uting S corporation, rather than the fair
market value of the contribution, this rule
provides greater certainty to both taxpay-
ers and the IRS. The regulations do not
require the contributing partnership or
contributing S corporation to claim the full
amount of the contribution that it might
otherwise claim in the absence of the Dis-
allowance Rule. Therefore, a contributing
partnership or contributing S corporation
making a contribution that would other-
wise be disallowed by the Disallowance
Rule could avoid the Disallowance Rule
by claiming an amount of qualified con-
servation contribution that is less than or
equal to 2.5 times the sum of the relevant
bases, assuming that the claimed amount
is not more than the fair market value of
the contribution. Thus, taxpayers may be
able to mitigate the “cliff effect” noted by
the commenter.
In accordance with section 170(h)
(7)(G), which provides authority for the
Secretary to prescribe such regulations
or other guidance as may be necessary
or appropriate to carry out the purposes
of section 170(h)(7), including to prevent
the avoidance of the purposes of section
170(h)(7), these final regulations also
provide that, if a partner or S corporation
shareholder claims an amount of qualified
conservation contribution that is inconsis-
tent with and greater than the amount of
the partner’s distributive share or S corpo-
ration shareholder’s pro rata share of qual-
ified conservation contribution reported to
the partner or S corporation shareholder
by the partnership or S corporation, pred-
icated on a position that the partnership’s
or S corporation’s qualified conservation
contribution was a greater amount than
the amount claimed by the partnership
or S corporation, and the qualified con-
servation contribution would have been a
disallowed qualified conservation contri-
bution if the partnership or S corporation
had actually claimed that greater amount,
then the partner’s or S corporation share-
holder’s claimed qualified conservation
contribution is a disallowed qualified con-
servation contribution. This rule is neces-
sary to avoid situations in which a partner
or an S corporation shareholder seeks to
avoid the application of section 170(h)(7)
by claiming an amount with respect to a
qualified conservation contribution that
is more than the amount allocated to the
partner or shareholder and reported by the
partnership or S corporation.
E. Statement regarding taxpayers to
whom the Disallowance Rule does not
apply
One commenter stated that the proposed
regulations lacked clarity as to which pro-
visions apply to every contributing part-
nership or contributing S corporation and
requested that the final regulations include

July 22, 2024 92 Bulletin No. 2024–30
a preliminary explanation of scope. The
commenter recommended that, if dif-
ferent provisions have different scopes,
then that should be made clear. The com-
menter recommended that the final regu-
lations explicitly state that §1.170A-14(j)
through (n) does not apply to qualified
conservation contributions made by indi-
viduals, joint tenancies, tenancies in com-
mon, or C corporations. The commenter
also recommended that the final regula-
tions explicitly state that §1.170A-14(j)
through (n) does not apply to partnerships
and entities taxed as partnerships: (1)
which have held the real property subject
to the qualified conservation contribu-
tion for more than one year immediately
before the date and hour of the qualified
conservation contribution, disregarding
any tacked holding period; and (2) all of
whose members, on the date and time of
the qualified conservation contribution,
have held the same percentage interest in
the partnership, directly or indirectly, dis-
regarding any tacked holding period, for
more than one year immediately before
the date and hour of the qualified conser-
vation contribution.
With respect to the request to clarify
that §1.170A-14(j) through (n) does not
apply to qualified conservation contri-
butions made by individuals, joint ten-
ancies, tenancies in common, or by C
corporations, the Treasury Department
and the IRS agree in part. Section 170(h)
(7)(A) and (F) provide that the Disallow-
ance Rule applies only to certain quali-
fied conservation contributions made by
partnerships, S corporations, and other
pass-through entities; thus, it does not
apply to qualified conservation contri-
butions made by individuals or C cor-
porations. However, in certain cases an
arrangement that is a joint tenancy or
tenancy in common under State law may
be considered a partnership for Federal
tax purposes. See §301.7701-1(a)(2). If
so, a qualified conservation contribution
by such an arrangement would be subject
to the Disallowance Rule. Accordingly,
§1.170A-14(j)(1) of these final regula-
tions includes a statement that the Disal-
lowance Rule does not apply to qualified
conservation contributions made directly
by landowners that are not pass-through
entities, such as individuals or C corpo-
rations.
With respect to the request to clarify
that §1.170A-14(j) through (n) does not
apply to partnerships and entities taxed
as partnerships: (1) which have held the
real property subject to the qualified con-
servation contribution for more than one
year immediately before the date and hour
of the qualified conservation contribu-
tion, disregarding any tacked-on holding
period and (2) all of whose members, on
the date and time of the qualified conser-
vation contribution, have held the same
percentage interest in the partnership,
directly or indirectly, disregarding any
tacked holding period, for more than one
year immediately before the date and hour
of the qualified conservation contribution,
the Treasury Department and the IRS
have concluded that such a rule would be
inconsistent with section 170(h)(7). As
explained in Part IV.A of this Summary
of Comments and Explanation of Revi-
sions, section 170(h)(7)(C) provides an
exception to the Disallowance Rule for
pass-through entities that satisfy a three-
year holding period. Accordingly, the final
regulations do not adopt this recommen-
dation.
V. Reporting Requirements
Section 170(f)(11)(H) grants the Trea-
sury Department and the IRS authority
to promulgate regulations to provide for
substantiation of a charitable contribution.
Section 170(h)(7)(G) grants the Treasury
Department and the IRS authority to pro-
mulgate regulations to carry out the pur-
poses of section 170(h)(7), including to
require reporting (including reporting
related to tiered partnerships and the mod-
ified basis of partners and S corporation
shareholders).
As noted in the preamble to the pro-
posed regulations, existing §1.170A-16
imposes substantiation and reporting
requirements for noncash charitable con-
tributions, including but not limited to
qualified conservation contributions by
pass-through entities. Subject to cer-
tain exceptions, §1.170A-16 requires the
donor to file Form 8283 in the case of a
noncash charitable contribution exceeding
$500. Specifically, existing §1.170A-16(c)
generally requires the donor to com-
plete Form 8283 (Section A) in the case
of a noncash charitable contribution
of more than $500 but not more than
$5,000. Existing §1.170A-16(d) generally
requires the donor to complete Form 8283
(Section A or Section B, as applicable)
in the case of a noncash charitable con-
tribution of more than $5,000. Existing
§1.170A-16(e) applies to noncash charita-
ble contributions of more than $500,000
and generally requires the donor to com-
plete Form 8283 (Section A or Section B,
as applicable). Section 170(f)(11)(D) and
existing §1.170A-16(e) require a donor
of a noncash contribution of more than
$500,000 to attach a qualified appraisal
to the return on which the deduction is
claimed. Existing §1.170A-16(f) provides
additional substantiation rules, including
rules for donors that are partnerships or S
corporations.
The proposed regulations provided
guidance in the following four categories:
(1) requirements for all noncash chari-
table contributions of more than $500,
(2) requirements for noncash charitable
contributions by partnerships and S cor-
porations, (3) requirements for quali-
fied conservation contributions made
by partnerships and S corporations, and
(4) requirements for qualified conserva-
tion contributions made by partnerships
and S corporations the conservation pur-
pose of which is the preservation of a cer-
tified historic structure.
A. Requirements for all noncash
charitable contributions of more than
$500
The proposed regulations made one
clarifying change applicable to all non-
cash charitable contributions of more than
$500—a requirement that taxpayers input
numerical entries into Form 8283.
Section 1.170A-16(c)(3) provides the
elements of a completed Form 8283 (Sec-
tion A), and §1.170A-16(d)(3) provides
the elements of a completed Form 8283
(Section B). To further clarify reporting
requirements for donated property, pro-
posed §1.170A-16(c)(3)(v) and (d)(3)(ix)
each added a requirement, respectively,
that, if a number can be inserted into any
box on Form 8283, the number must be
inserted in the box on Form 8283; alterna-
tively, taxpayers may attach a statement to
the Form 8283 explaining why a number
cannot be inserted. The proposed regula-

Bulletin No. 2024–30 93 July 22, 2024
tions also clarified that, while nothing pre-
cludes a taxpayer from both inserting the
number in the appropriate box on Form
8283 and including an attached statement
explaining any additional information
regarding the number, taxpayers may not
respond to a request for information on
Form 8283 with nonresponsive responses,
for example, by indicating that the
requested information is available upon
request or will be provided upon request.
The proposed regulations provided that
inclusion of such nonresponsive language
in response to a request for information on
Form 8283 may be treated by the IRS as
being an incomplete filing of Form 8283.
The preamble to the proposed regu-
lations explained the IRS had observed
a pronounced increase in taxpayers fil-
ing a Form 8283 that did not contain any
numbers and instead referred the IRS to
an attachment. Often, the attachment
included nonresponsive information, such
as “available upon request,” was entirely
blank, or otherwise did not provide the
information required by Form 8283. Other
times, the attachment included multiple
numbers for different boxes, leaving the
IRS to figure out which of the included
numbers was appropriate for a particu-
lar box. The proposed regulations stated
that these actions are to the detriment of
fair and effective tax administration, and
stated,
While many taxpayers understand-
ably want to attach a statement to the
Form 8283 to verify their calculations
and provide appropriate supplemen-
tal information, having the numerical
information in the appropriate box on
Sections A and B of Form 8283 is crit-
ical to the IRS’s ability to ensure the
integrity of each filing, as IRS systems
are programmed to match a partner’s or
shareholder’s information to the appro-
priate contributing partnership’s or
contributing S corporation’s informa-
tion. Moreover, information requested
on Sections A and B of Form 8283 is
information that the partnership or S
corporation should already have and is
already required to provide to the part-
ner or shareholder, as appropriate.
A commenter suggested that confu-
sion could be avoided if the regulation
stated that an attached statement will only
be acceptable if it clearly explains why
the taxpayer cannot provide the basis of
their donation or is simply explanatory
of the basis the taxpayer provided. The
commenter also suggested that the box
requiring the taxpayer to report its basis
in the donated property could be left blank
if the taxpayer provided an explanatory
statement attached to the Form 8283. The
same commenter suggested that the regu-
lations add a box for the taxpayer to check
if the entire explanation and number are
contained in an attached statement. These
comments are largely already addressed
by the proposed regulations, which pro-
vided that taxpayers may attach a state-
ment to the Form 8283 explaining why a
number cannot be inserted and also clar-
ified that nothing precludes a taxpayer
from both inserting the number in the
appropriate box on Form 8283 and includ-
ing an attached statement explaining any
additional information regarding the num-
ber. The request to add a box to check if
the entire explanation and number are
contained in the attached statement is out-
side the scope of these final regulations
but will be considered in connection with
updates to the Form 8283.
One commenter agreed with the Trea-
sury Department and the IRS’s “general
attitude toward Form 8283 and taxpay-
ers who leave information blank,” but
requested that the Form 8283 include a
box to disclose tacked holding periods.
This commenter noted that the Form
8283 currently only contains a box for
“date acquired by donor” and stated that
accountants had expressed confusion over
whether acquisition date or holding period
date ought to be inserted into that box,
because the holding period date is the rel-
evant date for all other accounting and tax
purposes. The commenter suggested that
adding a box for the holding period would
account for potential disparities between
the date entered in the “date acquired by
donor” box and the actual date when a
donor’s holding period began to run.
The request to add a box for the hold-
ing period is outside the scope of these
final regulations but will be considered
in connection with updates to the Form
8283. The Treasury Department and IRS
emphasize that current instructions to
Form 8283 direct taxpayers to enter the
date the property is acquired by the donor
and that taxpayers may submit an attach-
ment disclosing the tacked holding period
to explain potential disparities between
the date acquired by the donor and the
date the donor’s holding period began to
run.
This commenter also suggested that
any increase in the number of taxpayers
filing Forms 8283 that do not contain
numbers and instead refer the IRS to an
attachment is evidence of taxpayer con-
fusion on how to fill out the Form 8283,
“particularly when the IRS has taken a lit-
igating position that attempts to disqualify
deductions in numerous easement cases
based on alleged failures in the taxpay-
ers’ Forms 8283.” The commenter sug-
gested that the final regulations should
not discourage taxpayers from providing
additional information on an attachment,
particularly if the taxpayer is doing so
to supplement information on the Form
8283. This comment is consistent with the
proposed regulations, which provided that
taxpayers may attach a statement to the
Form 8283 explaining why a number can-
not be inserted and also clarified that noth-
ing precludes a taxpayer from both insert-
ing the number in the appropriate box
on Form 8283 and including an attached
statement explaining any additional infor-
mation regarding the number.
This commenter also proposed that the
regulations include a “substantial com-
pliance” standard for Form 8283 for tax-
payers who make a good faith effort to
complete the form. The commenter stated
that substantial compliance relief should
not apply if a taxpayer omits information
from Form 8283 altogether or otherwise
manipulates the form, but that if a tax-
payer makes a good-faith mistake, such as
miscalculating basis in a way that does not
affect the calculation of whether a quali-
fied conservation contribution exceeds 2.5
times the sum of the relevant bases, the
taxpayer should not be punished by hav-
ing its deduction denied altogether.
While the IRS may work with a tax-
payer to fix a good-faith mistake, the
Treasury Department and the IRS decline
to adopt a “substantial compliance” stan-
dard for Form 8283. First, there are certain
reporting requirements that are statutorily
imposed and cannot be satisfied through
substantial compliance, including the

July 22, 2024 94 Bulletin No. 2024–30
requirement to obtain a qualified appraisal
and attach an appraisal summary to the
return. See Hewitt v. Commissioner, 109
T.C. 258, aff ’d without published opin-
ion, 166 F.3d 332 (4th Cir. 1998); Deficit
Reduction Act of 1984 (DEFRA), Public
Law No. 98-369, section 155(a)(3), 98
Stat. 494 (1984). Second, even for those
reporting requirements that may implicate
the substantial compliance doctrine, the
determination of whether substantial com-
pliance should apply is made under com-
mon law and should be applied only in
cases in which the taxpayer acted in good
faith and exercised due diligence but nev-
ertheless failed to meet regulatory require-
ments. See Prussner v. U.S., 896 F.2d 218,
224 (7th Cir. 1990). See also McAlpine
v. Commissioner, 968 F.2d 459, 462 (5th
Cir. 1992). Substantial compliance is not
applicable if the requirement is essential
but may be applied if the requirements
are procedural or directory. See Estate of
Strickland v. Commissioner, 92 T.C. 16,
27 (1989). The determination of whether
substantial compliance is satisfied is a
facts-and-circumstances analysis that is
ordinarily resolved through the examina-
tion, Appeals, or judicial process.
One commenter noted that the require-
ment to report cost basis has been in exis-
tence since 1988 and stated that some
practitioners have failed to scrupulously
report either the cost basis, fair market
value, or both, maintaining that an earlier
iteration of the Form 8283 instructions
were vague as to this requirement. The
commenter asked that the final regulations
“remove all doubt and reaffirm that the
reporting requirement was never vague or
ambiguous.”
The Treasury Department and the IRS
agree that the requirements for an accu-
rate Form 8283 have always required
the reporting of cost or other basis in
the donated property. Section 155(a)
(1) of DEFRA specifically instructs the
Secretary to promulgate regulations that
require a taxpayer claiming a deduction
for a noncash charitable contribution to:
(1) obtain a qualified appraisal for the
property, (2) attach an appraisal summary
to the return on which such deduction is
first claimed for such contribution, and
(3) include on such return such additional
information (including the cost basis and
acquisition date of the contributed prop-
erty) as the Secretary may prescribe in
such regulations. (Emphasis added). In
fulfillment of this mandate, the Secretary
promulgated §1.170A-13, Recordkeep-
ing and Return Requirements for Deduc-
tions for Charitable Contributions. TD
8002, 49 FR 50663, December 31, 1984.
Section 1.170A-13(b)(3)(i)(B) requires
reporting cost or other basis for charita-
ble contribution deductions in excess of
$500 if required by the return form or its
instructions. Section 1.170A-13(b)(3)(ii)
provides that, if a taxpayer has reasonable
cause for being unable to provide such
information, the taxpayer must attach
an explanatory statement to the return.
Existing §1.170A-16(c)(3)(iv)(F) and (d)
(3)(vi) require the reporting of cost or
other basis on Form 8283. Additionally,
section 170(f)(11)(B) and (C) provide the
Secretary the authority to require infor-
mation other than property descriptions
for contributions of more than $500 and
requires qualified appraisals for contri-
butions of more than $5,000. These final
regulations clarify requirements for com-
pleting certain fields on Form 8283, but
the requirement to include cost basis is
clear under existing regulations and does
not require reiterating in other parts of
the regulations, including in these final
regulations.
Accordingly, proposed §1.170A-16(c)
(3)(v) and (d)(3)(ix) are finalized with
only minor, non-substantive changes
(such as using the term “non-responsive
language” instead of the term “non-re-
sponsive responses”).
B. Requirements for noncash charitable
contributions over $500 by partnerships
and S corporations
Existing §1.170A-16(f)(4)(i) pro-
vides that, if a partnership or S cor-
poration makes a noncash charitable
contribution, the partnership or S cor-
poration is required to provide a copy
of its completed Form 8283 (Section A
or Section B) to every partner or share-
holder who receives an allocation of a
charitable contribution deduction under
section 170. Similarly, a recipient part-
ner or shareholder that is a partnership
or S corporation must provide a copy of
the completed Form 8283 to each of its
partners or shareholders who receives
an allocation of a charitable contribution
deduction under section 170 for the prop-
erty described in Form 8283. Proposed
§1.170A-16(f)(4)(i) retained these rules
and clarified that any additional tiers of
pass-through entities must also provide
a copy of the donor’s Form 8283 to its
partners or shareholders who receive an
allocation of the charitable contribution.
Existing §1.170A-16(f)(4)(ii) requires
a partner or S corporation shareholder
that receives an allocation of a charita-
ble contribution to which §1.170A-16(c),
(d), or (e) applies to attach a copy of the
partnership’s or S corporation’s com-
pleted Form 8283 (Section A or Section
B) to the return on which the deduction
is claimed. Proposed §1.170A-16(f)(4)(ii)
retained these rules and clarified that the
partner or shareholder must also attach a
copy of any additional Forms 8283 that
must be provided to them under proposed
§1.170A-16(f)(4)(iii)(A).
Proposed §1.170A-16(f)(4)(iii)(A)
provided that a partner of a partnership
or shareholder of an S corporation that
receives an allocation of a charitable con-
tribution to which §1.170A-16(c), (d), or
(e) applies must complete its own Form
8283 with any information required by
Form 8283 and the instructions to Form
8283. In addition, proposed §1.170A-16(f)
(4)(iii)(A) provided that a partner that is
itself a partnership or S corporation must
complete its own Form 8283 and provide
a copy of that Form 8283 to every partner
or shareholder who receives an allocation
of the charitable contribution, and so on
through any additional tiers. Proposed
§1.170A-16(f)(4)(iii)(A) required each
partner or shareholder to attach its sep-
arate Form 8283 to the return on which
the contribution is claimed, in addition
to the copy of the donor’s Form 8283 as
well as other Forms 8283 that the partner
or shareholder received. This proposed
requirement applied to all noncash char-
itable contributions over $500 made by a
partnership or S corporation, not just those
for conservation easements.
The comments received on these provi-
sions addressed: (1) the requirement that
partners and S corporation shareholders
complete and file separate Forms 8283,
and (2) donee responsibilities pertaining
to the partners’ and shareholders’ Forms
8283.

Bulletin No. 2024–30 95 July 22, 2024
1. The Form 8283 Filing Requirement for
Partners and Shareholders
One commenter addressed proposed
§1.170A-16(f)(4)(iii)(A). This com-
menter suggested that, rather than requir-
ing partners and S corporation sharehold-
ers to complete and file separate Forms
8283, the donating partnership or S cor-
poration should be required to include
on its Form 8283 information about the
partners’ and shareholders’ bases and
holding periods. The commenter sug-
gested retaining the “current approach”
of having one Form 8283 for the con-
tributing partnership (that is distributed
to the partners) and then requiring the
specific information the IRS is seeking
on the attachment (which is required for
all qualified conservation contributions)
submitted by the partners.
Section 170(f)(11) disallows a charita-
ble contribution deduction unless certain
substantiation requirements are met. Pro-
viding a Form 8283 is a reasonable, basic
step for substantiating charitable con-
tributions for taxpayers who ultimately
claim the deduction. Congress provided,
as part of DEFRA, the authority to require
taxpayers to submit Forms 8283. The
legislative history shows that Congress
was concerned that “opportunities to off-
set income through inflated valuations of
donated property have been increasingly
exploited by tax shelter promoters.”
Staff of Senate Comm. on Finance, 98th
Cong., 2d Sess., Explanation of Provi-
sions of the Deficit Reduction Act of
1984, at 503 (Comm. Print 1984). This
has long been an area of abuse for which
taxpayers have creatively sought to avoid
transparent reporting and instead have
attempted to disguise overvalued charita-
ble contributions.
Proposed §1.170A-16(f)(4)(iii)(A)
provides the IRS with important informa-
tion and the burden imposed on taxpayers
is reasonable in light of the potential for
abuse. As the preamble to the proposed
regulations stated, in pass-through and
tiered-entity structures, the IRS regu-
larly observes partners and sharehold-
ers providing incomplete information to
substantiate their charitable contribution
deductions. A partner’s or S corpora-
tion shareholder’s Form 8283 that con-
tains the necessary information from the
Form K-1 received from the donating
partnership, donating S corporation, or
an upper-tier partnership or upper-tier S
corporation streamlines processing and
efficiency. Thus, these final regulations
finalize §1.170A-16(f)(4)(iii)(A) as pro-
posed.
2. Donee Responsibilities Pertaining to
Partners’ and Shareholders’ Forms 8283
A commenter stated that the require-
ment that partners and S corporation
shareholders provide their own Form
8283 represents substantial additional
work for donees that likely would make
them less willing (and able) to assess the
accuracy and completeness of Form 8283.
This commenter stated that, if there is an
expectation that the donee would sign an
individual’s Form 8283, then it would
require more due diligence for the donee,
creating on-the-ground problems and com-
plexities. The commenter also stated that
retaining so many copies of Forms 8283
as part of their permanent record would
significantly increase their record-keep-
ing burden (although this commenter also
stated that the great majority of conserva-
tion easement donations are not made by
partnerships and, of those, very few are
made by tiered partnerships).
The proposed regulations did not
impose a requirement for the donee to sign
and/or retain a copy of each partner’s and
shareholder’s Forms 8283. The require-
ment in §1.170A-16(d)(3)(ii) that a com-
pleted Form 8283 (Section B) include the
donee’s signature only applies to the Form
8283 filed by the donor, in these instances
the contributing pass-through entity. To
clarify this issue, the Instructions to Form
8283 have been updated to provide: “A
member’s Form 8283 is not required
to have signatures.” See the Form 8283
Instructions released on January 17, 2024,
which state “(Rev. December 2023)” after
“Instructions for Form 8283” at the top of
the first page.
C. Requirements for qualified
conservation contributions made by
partnerships and S corporations
As explained in the preamble to the
proposed regulations, to ensure that tax-
payers claiming qualified conservation
contributions properly comply with sec-
tion 170(f)(19) and (h)(7), the IRS must
have relevant basis reporting from both
the contributing partnership or contrib-
uting S corporation and each partner or
shareholder receiving an allocation of
the contribution (which will be ultimate
members, upper-tier partnerships, or
upper-tier S corporations). Accordingly,
the proposed regulations inserted a new
paragraph, proposed §1.170A-16(d)(3)
(viii),
5
which provided that, for qualified
conservation contributions made by a
partnership or S corporation, the contrib-
uting partnership or contributing S corpo-
ration must report the sum of each ulti-
mate member’s relevant basis, computed
in accordance with §1.170A-14(j) through
(m), on the Form 8283 (Section B). Under
proposed §1.170A-16(d)(3)(viii), this
new requirement did not apply to con-
tributions described in section 170(h)(7)
(C) and §1.170A-14(n)(2) (for contri-
butions made outside of the three-year
holding period) or section 170(h)(7)(D)
and §1.170A-14(n)(3) (for contributions
made by certain family partnerships or
S corporations), provided that they are not
also described in section 170(h)(7)(E) and
§1.170A-14(n)(4) (for contributions to
preserve certified historic structures), in
which case the reporting requirement did
apply.
Proposed §1.170A-16(f)(4)(iii)(B)
provided an additional substantiation rule
for partners and S corporation sharehold-
ers receiving an allocation of a qualified
conservation contribution. That paragraph
required that an ultimate member’s sep-
arate Form 8283 must include the ulti-
mate member’s own relevant basis and
that an upper-tier partnership’s or upper-
tier S corporation’s separate Form 8283
must include the sum of each of its ulti-
mate member’s relevant bases. Proposed
§1.170A-16(f)(4)(iii)(B) did not apply to
5
The proposed regulations would redesignate existing §1.170A-16(d)(3)(viii) as §1.170A-16(d)(3)(x).

July 22, 2024 96 Bulletin No. 2024–30
contributions described in section 170(h)
(7)(C) and §1.170A-14(n)(2) (for contri-
butions made outside of the three-year
holding period) or section 170(h)(7)(D)
and §1.170A-14(n)(3) (for contributions
made by certain family partnerships or
S corporations), provided that they are
not also described in section 170(h)(7)
(E) and §1.170A-14(n)(4) (for contribu-
tions to preserve certified historic struc-
tures), in which case proposed paragraph
§1.170A-16(f)(4)(iii)(B) did apply.
The comments received on these pro-
visions addressed: (1) the requirement
that ultimate shareholders report relevant
basis, (2) whether the contributing entity
should report the basis in the property
underlying the qualified conservation
contribution or the basis in the qualified
conservation contribution itself, and (3)
requiring reporting of relevant basis with
respect to a qualified conservation contri-
bution that satisfies one of the exceptions
to the Disallowance Rule.
1. The Requirement that Ultimate
Members Report Relevant Basis
One commenter interpreted the require-
ment in the proposed regulations that ulti-
mate members report their relevant basis
on their separate Forms 8283 to mean
that the proposed regulations “require
individual members and shareholders to
determine their relevant basis and hold-
ing period.” The commenter stated that a
particular problem with this new require-
ment is the complexity of the calculations
needed for an ultimate member to deter-
mine their relevant basis.
The Treasury Department and the IRS
disagree that the proposed regulations
require each ultimate member to deter-
mine its relevant basis. As explained in the
proposed regulations, relevant basis must
be determined by the partnership or S cor-
poration. The ultimate member may need
to share information, such as its basis in
its interest in the partnership or S corpora-
tion, with the partnership or S corporation
to facilitate this computation. The partner-
ship or S corporation must also determine
its holding period in the property with
respect to which the qualified conserva-
tion contribution is made.
Another commenter stated that the
requirement that partners and sharehold-
ers file a separate Form 8283 with respect
to certified historic structure contributions
was a trap for the unwary that was confus-
ing, duplicative, and contrary to the stat-
ute. In support of this premise, the com-
menter stated that: (1) the requirement
that each partner and shareholder file a
separate Form 8283 reporting its own
relevant basis does nothing to further the
purposes of section 170(f)(19) and (h)(7);
(2) section 170(f)(19) and (h)(7) apply at
the entity level based on the sum of all
the relevant bases, and the partners’ and
shareholders’ separate Forms 8283 do not
convey the sum of all the relevant bases;
(3) the Treasury Department and the IRS
could require the contributing partnership
to add an attachment to the Form 8283
explaining the partnership’s allocations
of the qualified conservation contribu-
tion, such as any contractual limitations
affecting the partnership’s allocations;
(4) requiring partners and shareholders to
report their relevant bases may cause con-
fusion by leading the partners and share-
holders to believe that application of the
Disallowance Rule depends on whether
the amount of a partner’s or shareholder’s
deduction exceeds 2.5 times the partner’s
or shareholder’s personal relevant basis;
(5) because section 170(f)(19) and (h)(7)
applies only to pass-through entities and
“almost all” pass-through entities are sub-
ject to audit at the entity level pursuant to
the Bipartisan Budget Act of 2015 (BBA),
the IRS does not need separate Forms
8283 at any intermediary partner levels;
and (6) the separate Forms 8283 from part-
ners and shareholders would not achieve
the intended result of reporting require-
ments enacted in DEFRA—triggering an
audit of overvalued property. The Trea-
sury Department and IRS have considered
these comments but conclude that they are
not persuasive. First, in a structure involv-
ing tiered partnerships or S corporations,
the Disallowance Rule must be tested at
each tier. See §1.170A-14(j)(2)(ii). There-
fore, each upper-tier partnership and
upper-tier S corporation must compute
2.5 times the sum of its ultimate members’
relevant bases. It may be the case that the
amount of the contributing partnership’s
contribution does not exceed 2.5 times
the sum of its ultimate members’ relevant
bases, but an upper-tier partnership’s allo-
cated portion does exceed 2.5 times the
sum of the upper-tier partnership’s ulti-
mate members’ relevant bases and would
be subject to the Disallowance Rule.
Therefore, it is essential that each upper-
tier partnership and upper-tier S corpora-
tion provide a separate Form 8283 so that
the IRS can apply the Disallowance Rule
to upper-tier partnerships and upper-tier
S corporations. Second, section 170(h)(7)
(G)(i) provides an explicit grant of author-
ity for the promulgation of regulations
and other guidance requiring reporting
related to tiered partnerships and S corpo-
rations. Requiring upper-tier partnerships
and upper-tier S corporations to report the
sum of their ultimate members’ relevant
bases is necessary to administer the Dis-
allowance Rule and is consistent with the
authority granted in section 170(h)(7)(G).
Similarly, the requirement that an ulti-
mate member must report their own rel-
evant basis on their separate Form 8283
ensures that the relevant basis reported at
the ultimate member level is consistent
with the sum of relevant bases reported
by the partnership or S corporation. The
commenter’s suggestion that the partner-
ship’s or S corporation’s Form 8283 could
separately list each ultimate member’s rel-
evant basis would not be as administrable.
It is impractical for Form 8283 itself to
contain sufficient space for each ultimate
member’s relevant basis to be separately
listed. Accordingly, the partnership or
S corporation would need to provide such
information on an attachment or addi-
tional statement. The way in which such
an attachment is formatted, how easily the
information can be found, and whether or
not the information is actually provided
may vary. The Treasury Department and
the IRS have determined that requiring
ultimate members to report their personal
relevant bases in the appropriate box on
the Form 8283 (rather than on an attach-
ment to the form) ensures that the infor-
mation can be easily found by the IRS and
is in a uniform format for processing by
the IRS. Thus, even if a contributing part-
nership or upper-tier partnership is subject
to entity-level audit under the BBA, the
partners’ separate Forms 8283 provide
valuable information in ascertaining the
partnership’s compliance with section
170(f)(19) and (h)(7).
In addition, the Treasury Department
and the IRS note that no S corporations

Bulletin No. 2024–30 97 July 22, 2024
and not all partnerships are subject to the
BBA audit procedures. Accordingly, the
Treasury Department and the IRS decline
to remove the requirement that partners
and S corporation shareholders report
their relevant bases on their separate
Forms 8283.
2. Whether the Contributing Entity
Should Report the Basis in the Property
Underlying the Qualified Conservation
Contribution or the Basis in the Qualified
Conservation Contribution Itself
As noted earlier, the regulations and
Form 8283 have long required a donor
to report its basis in the contributed
property. At the time of the publication
of the proposed regulations in Novem-
ber 2023, the then-current version of
the Form 8283 instructions allowed a
donor of a qualified conservation con-
tribution to either report its basis in
the underlying property or its basis in
the qualified conservation contribution
itself. For example, assume a partner-
ship owned 600 acres of real property.
The partnership donates a conservation
easement on 400 of those acres. Assume
the partnership’s adjusted basis in those
400 acres was $2,000,000, and that the
partnership’s adjusted basis in the con-
servation easement itself was $500,000.
Under the then-current version of the
Form 8283 instructions, the partnership
could list either $2,000,000 or $500,000
as its basis on the Form 8283; the part-
nership would also be required to indi-
cate whether it was reporting its basis
in the property underlying the qualified
conservation contribution or its basis in
the qualified conservation contribution
itself.
A commenter noted this option in the
(then-current) Form 8283 instructions.
The commenter stated that the proposed
regulations require a contributing part-
nership or contributing S corporation to
provide its basis in the property under-
lying the qualified conservation contribu-
tion rather than its basis in the qualified
conservation contribution itself. This
commenter believed it would simplify
the process for the donor, donee, and the
IRS if Form 8283 required all taxpayers
making a qualified conservation contri-
bution to report their basis in the property
underlying the qualified conservation
contribution, rather than giving taxpay-
ers a choice.
The Treasury Department and the IRS
note that the proposed regulations do not
amend the requirement in §1.170A-16(d)
(3)(vi) that taxpayers report their basis
in contributed property on their Forms
8283. Section 170(h)(7)(B)(i) provides
that, for purposes of the Disallowance
Rule, relevant basis is determined with
reference to “the portion of the real prop-
erty with respect to which” the quali-
fied conservation contribution is made.
Accordingly, the computations in the
proposed regulations are generally based
on the contributing partnership’s or con-
tributing S corporation’s basis in the
property underlying the qualified conser-
vation contribution, rather than its basis
in the qualified conservation contribution
itself.
Although the proposed regulations do
not modify the requirement that a donor
must report its basis in contributed prop-
erty, the Treasury Department and the
IRS note that the current version of the
Form 8283 instructions, released January
17, 2024, which states “(Rev. December
2023)” after “Instructions for Form 8283”
at the top of the first page, requires a donor
of a qualified conservation contribution
to both report its basis in the underlying
real property on Form 8283 and include
information about the cost or adjusted
basis of the qualified conservation con-
tribution itself in a statement attached to
Form 8283.
3. Requiring Reporting of Relevant Basis
with Respect to a Qualified Conservation
Contribution that Satisfies One of the
Exceptions to the Disallowance Rule
One commenter requested clarification
on whether the rule requiring Forms 8283
with relevant basis applied to every qual-
ified conservation contribution made by a
partnership or S corporation, regardless of
whether the contribution satisfies one of
the exceptions to the Disallowance Rule.
As noted above, proposed §1.170A-16(d)
(3)(viii) and (f)(4)(iii)(B) required con-
tributing partnerships, contributing S cor-
porations, upper-tier partnerships, upper-
tier S corporations, and ultimate members
to report relevant basis (or the sum of the
relevant bases) on Form 8283 with respect
to a qualified conservation contribution.
However, these reporting requirements
did not apply to contributions made out-
side of the three-year holding period or
to contributions made by certain family
partnerships or S corporations, unless the
contribution is to preserve a certified his-
toric structure (in which case the reporting
requirements did apply).
Because the regulations are already
clear on this point, the commenter’s sug-
gestion is not adopted. Accordingly, these
final regulations adopt §1.170A-16(d)(3)
(viii) and (f)(4)(iii)(B) with only minor
non-substantive changes.
D. Requirements for certified historic
structure contributions made by
partnerships and S corporations
Although contributions by partner-
ships or S corporations to preserve cer-
tified historic structures that exceed 2.5
times the sum of the relevant bases are
excepted from the Disallowance Rule,
they are subject to section 170(f)(19).
Section 170(f)(19) provides that no
deduction is allowed under section 170(a)
for such a contribution unless the pass-
through entity making such contribution
includes on its return for the taxable year
in which the contribution is made a state-
ment that the pass-through entity made
such a contribution and provides such
information about the contribution as the
Secretary may require. Section 170(f)
(19)(B) provides that section 170(f)(19)
applies to qualified conservation contri-
butions by pass-through entities (whether
directly or as a distributive share of a
contribution of another pass-through
entity) the conservation purpose of which
is the preservation of any building which
is a certified historic structure, and the
amount of which exceeds 2.5 times the
sum of each partner’s relevant basis (as
defined in section 170(h)(7)).
Proposed §1.170A-16(f)(6)(i) pro-
vided that, for any qualified conserva-
tion contribution described in proposed
§1.170A-16(f)(6)(ii), no deduction is
allowed under section 170 or any other
provision of the Code under which
deductions are allowable to pass-
through entities with respect to such
contribution unless each partnership or

July 22, 2024 98 Bulletin No. 2024–30
S corporation: (1) includes on its return
for the taxable year in which the contri-
bution is made a statement that it made
such a contribution or received such
allocated portion and (2) provides such
information about the contribution as
the Secretary may require in guidance,
forms, or instructions.
Proposed §1.170A-16(f)(6)(ii) pro-
vided that proposed §1.170A-16(f)(6)
applies to any qualified conservation
contribution, the conservation purpose
of which is preservation of a building
that is a certified historic structure, that
is either made by a contributing partner-
ship or contributing S corporation or that
is an allocated portion of an upper-tier
partnership or upper-tier S corporation,
and the amount of such contribution or
such allocated portion exceeds 2.5 times
the sum of each ultimate member’s rel-
evant basis.
Proposed §1.170A-16(f)(6)(iii) provided
that a partnership or S corporation satisfies
the requirements of section 170(f)(19)(A)
and §1.170A-16(f)(6)(i) by filing a com-
pleted Form 8283, including information
about relevant basis, in accordance with
section 170, the regulations under section
170, and the instructions to Form 8283.
As noted above, proposed
§1.170A-16(d)(3)(viii) and (f)(4)(iii)(B)
required contributing partnerships, con-
tributing S corporations, upper-tier part-
nerships, upper-tier S corporations, and
ultimate members to report relevant basis
(or the sum of the relevant bases) on Form
8283 with respect to any qualified conser-
vation contribution for the preservation of
a certified historic structure, regardless of
whether the contribution also satisfied the
three-year holding period exception or the
certain family pass-through entity excep-
tion.
Two commenters addressed these
rules, discussing whether: (1) relevant
basis accounts for fundamental differ-
ences between certified historic structure
contributions and other types of qualified
conservation contributions, (2) relevant
basis accurately reflects abusive certified
historic structure contributions, and (3)
these reporting requirements should apply
to certified historic structure contributions
that also satisfy either the three-year hold-
ing period exception or the family-pass
through entity exception.
1. Differences Between Certified Historic
Structure Contributions and Other Types
of Qualified Conservation Contributions
Two commenters expressed concern
that qualified conservation contributions
that satisfy the certified historic structure
exception are fundamentally different
than other types of qualified conservation
contributions (such as a conservation
easement to protect greenspace) and, as
such, the data used for computation of
relevant basis should be different. One of
these commenters stated that protection
of certified historic structures under sec-
tion 170(h)(4)(A)(iv) differs fundamen-
tally from other conservation purposes
in section 170(h)(4)(A)(i) through (iii)
because “[u]nlike natural lands, which
typically do not need upkeep, historic
properties require a continuous influx
of capital for rehabilitation and ongoing
maintenance expenditures to preserve
the historic character of the building
protected by the easement.” This com-
menter added that “open space” qualified
conservation contributions allow nature
to thrive undisturbed while certified his-
toric structure contributions need addi-
tional human intervention to further the
conservation purpose and to preserve the
historic structure in perpetuity. The com-
menter stated that money flowing into the
property-owning partnership that is “put
toward the preservation, rehabilitation,
or upkeep of the certified historic struc-
ture” should be allocated to the ultimate
member’s modified basis, but that the
proposed regulations “ignore these funds
entirely.”
The commenter offered an example of
a taxpayer that acquires a building and
then invests $2,000,000 into the build-
ing after acquisition. The commenter
stated that the proposed regulations
ignore both debt financing and capital
contributions made after the date of con-
tribution, which the commenter stated
“produces odd and unworkable results
for investors in historic structures,” and
recommended that the regulations be
amended to “include these other sources
of financing in historic properties.” The
commenter also stated that, “at the time
an easement is donated, cash from inves-
tors may be earmarked for preservation
and rehabilitation of a dilapidated struc-
ture.” The commenter remarked that cash
raised and debt secured is essential for
furthering the historic preservation pur-
pose. Thus, the commenter asserted that,
with respect to certified historic structure
contributions, the definition of relevant
or modified basis should include debt and
cash necessary for maintaining the con-
servation purpose.
The Treasury Department and the IRS
have concluded that certified historic
structure contributions should have the
same relevant basis computation as any
other qualified conservation contribution.
Although the Treasury Department and
the IRS recognize that there are differ-
ences between the conservation purposes
for different types of qualified conserva-
tion contributions, section 170(h)(7) does
not contemplate different calculations of
relevant basis depending on the particular
conservation purpose. Moreover, section
170(f)(19)(B)(iii) specifically refers to rel-
evant basis “as defined in [section 170(h)
(7)].”
It is appropriate that the rules for the
determination of modified basis and rel-
evant basis maintain their focus on the
amounts invested in the property gen-
erating the deduction as of the time of
the qualified conservation contribution.
Including debt and cash earmarked for the
ongoing maintenance of the conservation
purpose would contradict the statutory
definition of relevant basis and modified
basis. Section 170(h)(7)(B)(i) provides
that relevant basis means the portion of a
partner’s modified basis in the partnership
which is allocable to the portion of the real
property with respect to which a qualified
charitable contribution is made. This nar-
row definition of relevant basis does not
include amounts allocable to other assets.
Also, section 170(h)(7)(B)(ii)(I) provides
that modified basis is calculated imme-
diately before the qualified conservation
contribution. Including future events and
costs incurred or paid after the donation
would defeat the purpose of including
a timeline in the definition of modified
basis.
Therefore, the final regulations do not
provide for different calculations for rele-
vant basis depending on different conser-
vation purposes. In addition, the compu-
tations for relevant basis would not treat
“earmarked” amounts as part of the prop-

Bulletin No. 2024–30 99 July 22, 2024
erty with respect to which the qualified
conservation contribution is made. Thus,
for example, such amounts would not be
included in items A
6
or E
7
in the relevant
basis computations.
2. The Use of Relevant Basis in
Identifying Abusive Certified Historic
Structure Contributions
One of the commenters stated that
relevant basis is not an accurate measure
to determine whether a certified historic
structure contribution is abusive, giving
the example of three buildings. The first
building is dilapidated, was purchased
for $100,000, and requires $900,000 of
improvements to reach a $1,000,000
investment value. The second building is
fully operational with a $1,000,000 acqui-
sition cost. It is possible for the owner to
enlarge either building under the appli-
cable zoning laws. The third building is
acquired for $5,000,000, but it is fully
developed and cannot be enlarged under
the applicable zoning laws. The owner
of each building makes a certified his-
toric structure contribution and claims a
$1,000,000 contribution.
The commenter stated that the
$100,000 dilapidated building would
be most in danger of demolition, yet the
ratio of the amount of the contribution to
the building’s basis would be 10:1, sug-
gesting an abusive transaction. The com-
menter stated that, with respect to the
second building, the ratio of the amount
of the contribution to the building’s basis
would be 1:1, and the ratio for the third
building would be 0.2:1. The commenter
concluded that, because the third build-
ing cannot be enlarged under applicable
zoning laws, the claimed contribution of
$1,000,000 would be the most abusive
of the three donations, yet would appear,
under the reporting requirements, as the
least abusive (because it would have the
lowest ratio). The commenter concluded
that this example illustrates that comput-
ing whether a certified historic structure
contribution exceeds 2.5 times the sum of
the relevant bases does not appropriately
provide relevant information for the IRS
to determine whether the claimed amount
of the contribution is abusive. The com-
menter stated that requiring reporting of
the sum of the relevant bases could actu-
ally lead the IRS away from identifying
abusive transactions.
The Treasury Department and the IRS
conclude that this comment is not persua-
sive and decline to make the changes that
it advocates. The purpose of these regu-
lations is to implement section 170(f)(19)
and (h)(7). Section 170(f)(19) explicitly
requires reporting for certified historic
structure contributions by partnerships
and S corporations that exceed 2.5 times
the sum of the relevant bases (as defined
in section 170(h)(7)). The fact that the
commenter believes that a different
reporting regime would have been more
helpful to the IRS does not change the
statutory framework with which taxpayers
must comply. Moreover, the fact pattern
described by the commenter raises con-
cerns about overvaluation and compliance
with section 170. In addition, the build-
ings most in need of preservation are those
with the greatest significance to American
history, not those in the poorest condition
with an ability to be enlarged. See 36 CFR
60.4 (criteria for National Register listing)
and 36 CFR 67.4 (criteria for certification
of historic significance).
This commenter also stated that rele-
vant basis for certified historic structure
contributions is particularly difficult to
compute. The commenter noted the “sheer
number and subjectivity of variables that
can affect the basis of a commercial build-
ing” and cited as examples the segregation
of furniture and fixtures from real property
and the determination of whether particu-
lar acquisition expenses should be capital-
ized or expensed. This commenter posited
a scenario in which the IRS disallowed a
deduction because of a disagreement over
whether carpeting should be capitalized
as part of furniture and fixtures or as part
of the basis in the building, because the
determination about how to capitalize that
item impacts the relevant basis calcula-
tion.
The Treasury Department and the IRS
note that the certified historic structure
exception in section 170(h)(7)(E) and
§1.170A-14(n)(4) provides that those
qualified conservation contributions are
not subject to the Disallowance Rule.
Under section 170(f)(19) and proposed
§1.170A-16(f)(6), however, any deduc-
tion will be disallowed if the amount of
the contribution exceeds 2.5 times the
sum of the relevant bases and the report-
ing requirements are not followed. The
commenter’s hypothetical is unrealistic
because the only way the capitalization
dispute would result in disallowance
under section 170(h)(7) or section 170(f)
(19) would be if the capitalization dis-
agreement resulted in the contribution
exceeding 2.5 times the sum of the rele-
vant bases and the taxpayer failed to com-
ply with the section 170(f)(19) reporting
requirements.
The commenter stated that, rather than
using relevant basis, the IRS should imple-
ment an alternative reporting regime that
would include “Valuation Assumptions”
and “Qualified Appraisal Information.” To
address valuation assumptions, the com-
menter suggested a “Critical Information
Summary for Historic Preservation Ease-
ment Appraisals.” The commenter hoped
that this proposal would make it much
more efficient to determine compliance
with the existing requirements and to find
the aspects of the appraisal that need addi-
tional review.
The second part of the commenter’s
reporting regime included a Qualified
Appraisal Checklist, which the com-
menter suggested would serve as a central
checklist for taxpayers to report adherence
to section 170(f)(11)(E)(ii)(II)
8
and sev-
eral requirements in the section 170 regu-
lations. The commenter stated that adopt-
ing such a checklist would be permissible
because the commenter interprets section
170(f)(19)(A)(ii) as “giving the Secretary
wide discretion in what information to
require.”
6
Item A is a contributing partnership’s adjusted basis in the portion of the real property with respect to which a qualified conservation contribution is made.
7
Item E is an ultimate member’s pro rata portion of a contributing S corporation’s adjusted basis in the portion of the real property with respect to which a qualified conservation contribution
is made.
8
Section 170(f)(11)(E)(ii)(ll) requires the appraiser to regularly perform appraisals for which the individual receives compensation. The commenter seems to imply that the Qualified
Appraisal Checklist more broadly satisfies the requirements of section 170(f)(11)(E) and corresponding regulations.

July 22, 2024 100 Bulletin No. 2024–30
The Treasury Department and the IRS
note that section 170(f)(19)(B) requires
that the taxpayer compute relevant basis,
as defined in section 170(h)(7), to deter-
mine if the taxpayer is required to report
under section 170(f)(19)(A). In other
words, although the statute grants author-
ity for the Treasury Department and the
IRS to require reporting of additional
information, the disallowance rule in
section 170(f)(19) for failure to report
required information depends on whether
the amount of the certified historic struc-
ture contribution exceeds 2.5 times the
sum of the relevant bases, as defined in
section 170(h)(7). Accordingly, the Trea-
sury Department and the IRS decline
to adopt the commenter’s suggestion to
replace the relevant basis calculation
required under section 170(f)(19)(B)(iii)
with this checklist. As noted in the pream-
ble to the proposed regulations, the Trea-
sury Department and the IRS intend to
issue future guidance addressing section
170(f)(19)(A)(ii).
3. Reporting Requirements for Certified
Historic Structure Contributions That
Also Satisfy Another Exception to the
Disallowance Rule
As described above, the proposed
regulations required the computing and
reporting of relevant basis with respect to
all contributions that satisfy the certified
historic structure exception. The proposed
regulations generally did not require the
computation or reporting of relevant basis
with respect to contributions that satis-
fied either the three-year holding period
exception or the family pass-through entity
exception. However, in a situation in which
a contribution satisfies both the certified
historic structure exception and one of the
other exceptions, the proposed regulations
did require the computing and reporting of
relevant basis. In addition, under proposed
§1.170A-16(f), if the amount of the certi-
fied historic structure contribution or allo-
cated portion exceeded 2.5 times the sum
of the relevant bases, then section 170(f)
(19) would disallow any deduction unless
the reporting requirements of proposed
§1.170A-16(f) were satisfied.
One commenter stated that computa-
tion and reporting of relevant basis should
not be required with respect to a contri-
bution that satisfies both the certified his-
toric structure exception and one of the
other exceptions. The commenter opined
that the rationale for the certified historic
structure exception relates to the capital
needs of operating buildings and not its
form of ownership. The commenter opined
that a qualified conservation contribution
does not present opportunities for abusive
arrangements if the form of ownership
qualifies for the three-year holding period
exception or the family pass-through entity
exception. The commenter further argued
that, had Congress been concerned about
reporting for the three-year holding period
exception or the family pass-through entity
exception, Congress would have imposed a
standalone reporting requirement for those
exceptions. The commenter suggested
that requiring participants in the other two
exceptions to follow the reporting require-
ments for certified historic structures may
serve as a deterrent to investment in cer-
tified historic structures or as a deterrent
to protecting certified historic structures
through a qualified conservation contribu-
tion.
The Treasury Department and the IRS
do not adopt this comment. Congress
drafted section 170(h)(7) so that a contri-
bution meeting any of the three statutory
exceptions in section 170(h)(7)(C), (D),
or (E) is not subject to the Disallowance
Rule. In contrast, Congress drafted the
reporting requirements in section 170(f)
(19) to apply to all certified historic struc-
ture contributions in excess of 2.5 times
the sum of the relevant bases, without
regard to whether the contribution satis-
fies the three-year holding period excep-
tion or the family pass-through exception.
Similarly, although section 170(h)(7)(C)
and (D) provide exceptions to the Dis-
allowance Rule, they do not provide an
exception to the reporting requirements of
section 170(f)(19). Accordingly, it would
not be consistent with the language or
purposes of section 170(f)(19) and (h)(7)
to exempt any certified historic structure
contributions from section 170(f)(19). In
addition, to ensure compliance with sec-
tion 170(f)(19), it is necessary that rele-
vant basis be reported for all certified his-
toric structure contributions. Thus, these
final regulations adopt §1.170A-16(d)(3)
(viii), (f)(4)(iii)(B), and (f)(6) as proposed
with minor non-substantive changes.
For clarity, these final regulations mod-
ify the recordkeeping requirements for
allocation of modified basis found in pro-
posed §1.170A-14(m)(6). As proposed,
contributing partnerships, contributing
S corporations, upper-tier partnerships,
and upper-tier S corporations must main-
tain dated, written statements in their
books and records by the due date, includ-
ing extensions, of their Federal income
tax returns, substantiating the computa-
tion of each ultimate member’s adjusted
basis, modified basis, and relevant basis,
but these statements need not be main-
tained (nor does modified basis or relevant
basis need to be computed) with respect
to contributions that meet an exception in
§1.170A-14(n)(2) or (3). These final reg-
ulations clarify that these statements must
be maintained (and modified basis and
relevant basis must be computed) with
respect to all contributions that meet the
certified historic structure exception in
§1.170A-14(n)(4), regardless of whether
such contributions also meet an exception
in §1.170A-14(n)(2) or (3). Accordingly,
these regulations finalize §1.170A-14(m)
(6) with a clarification to the second sen-
tence, which now provides that these state-
ments need not be maintained (nor does
modified basis or relevant basis need to be
computed) with respect to contributions
that meet an exception in §1.170A-14(n)
(2) or (3), unless the contribution also
meets the exception in §1.170A-14(n)(4)
(in which case these statements need to be
maintained and modified basis and rele-
vant basis need to be computed).
VI. Other Comments
Commenters also addressed: (1) the
proposed regulations’ consistency with the
Federal government’s position on climate
action, (2) the “no inference” paragraph in
the proposed regulations, (3) valuation of
qualified conservation contributions, and
(4) interaction of the Disallowance Rule
with the rules of section 1011(b) of the
Code.
A. Consistency with the Federal
government’s position on climate action
One commenter stated that the pro-
posed regulations evidenced an approach
to land conservation that is inconsistent

Bulletin No. 2024–30 101 July 22, 2024
with the Federal government’s position
regarding climate action as outlined at
the 2023 United Nations Climate Change
Conference (COP28).
The Treasury Department and the IRS
acknowledge the important role of climate
action, land conservation, and qualified
conservation contributions. Nevertheless,
Congress enacted section 170(f)(19) and
(h)(7) because of concerns regarding abu-
sive transactions and inflated claims. See,
e.g., S. Committee on Finance, Comm.
Print 116–44, Syndicated Conserva-
tion-Easement Transactions, 116th Cong.,
2nd Sess. (2020). The regulations under
§1.170A-14 implement the Disallowance
Rule.
B. No inference
Section 605(c)(2) of the SECURE 2.0
Act states that no inference is intended
as to the appropriate treatment of any
contribution for which a deduction is not
disallowed by reason of section 170(h)
(7). As explained in the preamble to
the proposed regulations, some practi-
tioners have taken the position that sec-
tion 170(h)(7) operates as a “safe har-
bor.” According to these practitioners, a
qualified conservation contribution that
is not disallowed by the Disallowance
Rule is somehow immune to a challenge
on other grounds, including failure to
comply with other rules under section
170 and overvaluation of the contri-
bution. The preamble to the proposed
regulations stated that such a position
is baseless and contradicted by the stat-
utory language. To clarify this issue,
proposed §1.170A-14(j)(5) provided
that there is no presumption that a qual-
ified conservation contribution that is
not a disallowed qualified conservation
contribution is compliant with section
170, any other section of the Code, the
regulations, or any other guidance there-
under. It also provided that compliance
with section 170(h)(7) and proposed
§1.170A-14(j) through (n) is not a safe
harbor for purposes of any other provi-
sion of law, including the other require-
ments of section 170 and the value of
the contribution. Such transactions are
subject to adjustment or disallowance
for any other reason, including failure to
satisfy the requirements of section 170
or the overvaluation of the contribution;
for example, failure to properly execute
Form 8283, violation of the partnership
anti-abuse rule of §1.701-2, lack of eco-
nomic substance, or other rules or judi-
cial doctrines. In addition, compliance
with proposed §1.170A-14(j) through
(n) would not preclude the application
of any penalty, including penalties for
valuation misstatement, negligence, and
fraud. Proposed §1.170A-14(j)(5) also
provided that taxpayers who engage in
such transactions may be required to
disclose, under §1.6011-4, the transac-
tions as listed transactions.
One commenter requested that the IRS
delete proposed §1.170A-14(j)(5). The
commenter stated that paragraph does not
add any value to the substance of the pro-
posed regulations and is “inappropriately
hostile toward donors of qualified conser-
vation contributions.”
The Treasury Department and the
IRS do not agree with this comment.
Proposed §1.170A-14(j)(5) implements
section 605(c)(2) of the SECURE 2.0
Act and provides further detail and clar-
ification about the interaction between
section 605(c)(2) of the SECURE 2.0 Act
and the other rules governing qualified
conservation contributions. Moreover,
as explained in the preamble to the pro-
posed regulations, the rule in proposed
§1.170A-14(j)(5) addresses positions
that some practitioners have actually
taken. Accordingly, these final regula-
tions retain §1.170A-14(j)(5) with minor
non-substantive changes.
C. Valuation of qualified conservation
contributions
One commenter expressed concern that
the proposed regulations do not address
the valuation of donated property, espe-
cially real property, nor do they address
fraudulent appraisal practices.
The Treasury Department and the IRS
agree that overvaluation is an important
facet of abusive charitable contributions
of interests in real property. However,
any guidance on valuation would be out-
side the scope of these final regulations,
which are focused on the Disallowance
Rule, section 170(f)(19), and reporting
requirements for noncash charitable con-
tributions. The Treasury Department and
the IRS have challenged and will continue
to challenge fraudulent appraisal practices
and overvaluation.
D. Interaction with the rules of section
1011(b)
Section 1011(b) provides that, if a
deduction is allowable under section 170
by reason of a sale, then the adjusted basis
for determining the gain from such sale is
that portion of the adjusted basis which
bears the same ratio to the adjusted basis
as the amount realized bears to the fair
market value of the property. The pro-
posed regulations do not address section
1011(b). One commenter asked about
the interaction of section 1011(b) with
the Disallowance Rule. Specifically, the
commenter asked whether the actual fair
market value of the qualified conserva-
tion contribution or the “capped amount”
under section 170(h)(7) should be used in
applying section 1011(b).
First, the Treasury Department and
the IRS disagree that section 170(h)(7) is
a “capped amount;” it is a Disallowance
Rule for certain qualified conservation
contributions by pass-through entities.
Second, by its terms, section 1011(b)
applies only if a deduction is allowable
under section 170 by reason of a sale.
Therefore, if a contribution is disallowed,
section 1011(b) would not apply.
Third, even in situations in which sec-
tion 1011(b) could apply, the application
of section 1011(b) is outside the scope of
these final regulations, and these final reg-
ulations do not address section 1011(b).
The Treasury Department and the IRS
note, however, that the computation of
adjusted basis for determining gain from
a sale described in section 1011(b) refers
to the fair market value of the property,
not the amount of the allowable deduction
under section 170.
Special Analyses
I. Regulatory Planning and Review
Pursuant to the Memorandum of
Agreement, Review of Treasury Regula-
tions under Executive Order 12866 (June
9, 2023), tax regulatory actions issued by
the IRS are not subject to the requirements
of section 6 of Executive Order 12866, as

July 22, 2024 102 Bulletin No. 2024–30
amended. Therefore, a regulatory impact
assessment is not required.
II. Paperwork Reduction Act
The Paperwork Reduction Act of 1995
(44 U.S.C. 3501-3520) generally requires
that a Federal agency obtain the approval
of the Office of Management and Bud-
get (OMB) before collecting information
from the public, whether such collection
of information is mandatory, voluntary,
or required to obtain or retain a benefit.
An agency may not conduct or sponsor,
and a person is not required to respond
to, a collection of information unless the
collection of information displays a valid
control number.
The collection of information con-
tained in these final regulations is reflected
in the collection of information for Form
8283, Noncash Charitable Contributions,
and Schedule K-1 for Forms 1065, U.S.
Return of Partnership Income, and 1120-
S, U.S. Income Tax Return for an S cor-
poration, that have been reviewed and
approved by the Office of Management
and Budget in accordance with the Paper-
work Reduction Act (44 U.S.C. 3507(c))
under control numbers 1545-0074 and
1545-0123. The preamble to the proposed
regulations stated that the estimated bur-
den for taxpayers filing Form 8283 under
OMB control number 1545-0074 is nine-
teen minutes for recordkeeping, twen-
ty-nine minutes for learning about the law
or the form, one hour and four minutes for
preparing the form, and thirty-four min-
utes for copying, assembling, and sending
the form to the IRS.
Two commenters raised concerns with
the taxpayer burden. One commenter
stated that the burden to learn these rules
was unreasonable. Another commenter
stated that the proposed estimated time
burdens for Form 8283 drastically under-
estimated the time necessary for a taxpayer
to understand and apply the regulations. As
explained in this preamble, these regula-
tions are promulgated under the authority
of section 170(h)(7) and other provisions
in the Code, are consistent with the lan-
guage and purposes of section 170(f)(19)
and (h)(7), and the Treasury Department
and the IRS have determined that they
are not more burdensome than necessary.
Accordingly, the burden imposed by these
final regulations is reasonable. However,
the Treasury Department and the IRS will
evaluate the estimated time for a taxpayer
to understand and apply the regulations
and will reflect any revisions in the Form
8283 burden estimates. To the extent there
is a change in burden as a result of these
regulations, the change in burden will be
reflected in the updated burden estimates
for the Form 8283 and Schedule K-1 for
Forms 1065 and 1120-S. The requirement
to maintain records to substantiate infor-
mation on Form 8283 and Schedule K-1
for Forms 1065 and 1120-S is already
contained in the burden estimates associ-
ated with the control number for the forms
and remains unchanged.
III. Regulatory Flexibility Act
The Secretary of the Treasury hereby
certifies that these final regulations will
not have a significant economic impact on
a substantial number of small entities pur-
suant to the Regulatory Flexibility Act (5
U.S.C. chapter 6). These final regulations
affect partnerships and S corporations
that claim qualified conservation contri-
butions as well as partners and S corpo-
ration shareholders that receive a distrib-
utive share or pro rata share of a noncash
charitable contribution. Although data is
not readily available about the number of
small entities that are potentially affected
by this rule, it is possible that a substantial
number of small entities may be affected.
The impact of these final regulations
can be described in the following five cat-
egories.
First, §1.170A-14(j) through (n) pro-
vides guidance in applying section 170(h)
(7), including providing definitions, for-
mulas for the required calculations, and
examples to help ensure the effective
application of section 170(h)(7), and
§§1.706-3 and 1.706-4(e)(2)(xiii) provide
special rules for allocating qualified con-
servation contributions. Even assuming
that these provisions affect a substantial
number of small entities, they will not
have a significant economic impact. Sec-
tion 170(h)(7) is self-executing and the
statute imposes the burden of calculating
relevant basis and applying the Disallow-
ance Rule. Because these final regulations
are focused on providing definitional and
computational guidance related to sec-
tion 170(h)(7), their economic impact is
expected to be minimal.
Second, §1.170A-14(m)(6) generally
requires contributing partnerships, con-
tributing S corporations, upper-tier part-
nerships, and upper-tier S corporations to
maintain dated, written statements in their
books and records, by the due date, includ-
ing extensions, of their Federal income tax
returns, substantiating the computation of
each ultimate member’s adjusted basis,
modified basis, and relevant basis. Even
assuming that this provision affects a sub-
stantial number of small entities, it will
not have a significant economic impact
because partnerships and S corporations
generally need to create these statements
by the due date of their Federal income tax
returns to ensure that they have complied
with the requirements of section 170(h)
(7) and (f)(19), which are self-executing.
Therefore, this provision simply requires
partnerships and S corporations to main-
tain something that they generally have
already created.
Third, §1.170A-16(d)(3)(viii) requires
the Form 8283 filed by contributing part-
nerships and contributing S corporations
to include the sum of each ultimate mem-
ber’s relevant basis. The existing regula-
tions under §1.170A-16 already require
these entities to file Form 8283. Even
assuming that this provision affects a sub-
stantial number of small entities, it will
not have a significant economic impact
because it simply requires contributing
partnerships and contributing S corpora-
tions to put a small amount of additional
information, which section 170(h)(7) and
(f)(19) requires them to determine, on a
form they are already required to file.
Fourth, §1.170A-16(f)(6) requires
a partnership or S corporation to file a
completed Form 8283 to be considered to
satisfy the requirements of section 170(f)
(19)(A). Even assuming that this provi-
sion affects a substantial number of small
entities, it will not have a significant eco-
nomic impact because it simply requires
contributing partnerships and contributing
S corporations to complete a form they are
already required to file.
Fifth, §1.170A-16(f)(4)(iii) requires
all partners and shareholders of S cor-
porations who receive an allocation of a
noncash charitable contribution to file a
separate Form 8283. Many of these part-

Bulletin No. 2024–30 103 July 22, 2024
ners and shareholders will be individuals,
not small entities. However, even assum-
ing that this provision affects a substantial
number of small entities, it will not have
a significant economic impact. The part-
nership or S corporation will provide the
partner or shareholder with all, or substan-
tially all, of the information to be reported
on the separate Form 8283; this informa-
tion will be contained either on the part-
nership’s or S corporation’s Form 8283 or
the Schedule K-1 issued to the partner or
shareholder. Accordingly, in most cases,
partners and shareholders will simply be
transcribing information provided to them
onto the separate Form 8283.
For the reasons stated, a regulatory
flexibility analysis under the Regulatory
Flexibility Act is not required. Pursuant to
section 7805(f) of the Code, the proposed
rule preceding these final regulations was
submitted to the Chief Counsel for Advo-
cacy of the Small Business Administration
for comment on its impact on small busi-
ness. No comments were received from
the Chief Counsel for Advocacy of the
Small Business Administration.
IV. Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandate
Reform Act of 1995 (UMRA) requires
that agencies assess anticipated costs and
benefits and take certain other actions
before issuing a final rule that includes
any Federal mandate that may result in
expenditures in any one year by a State,
local, or Tribal government, in the aggre-
gate, or by the private sector, of $100
million (updated annually for inflation).
These final regulations do not include any
Federal mandate that may result in expen-
ditures by State, local, or Tribal govern-
ments or by the private sector in excess of
that threshold.
V. Executive Order 13132: Federalism
Executive Order 13132 (Federalism)
prohibits an agency from publishing any
rule that has federalism implications if
the rule either imposes substantial, direct
compliance costs on State and local gov-
ernments, and is not required by statute,
or preempts State law, unless the agency
meets the consultation and funding
requirements of section 6 of the Executive
order. These final regulations do not have
federalism implications and do not impose
substantial, direct compliance costs on
State and local governments or preempt
State law within the meaning of the Exec-
utive order.
VI. Executive Order 13175: Consultation
and Coordination With Indian Tribal
Governments
Executive Order 13175 (Consultation
and Coordination With Indian Tribal Gov-
ernments) prohibits an agency from pub-
lishing any rule that has Tribal implica-
tions if the rule either imposes substantial,
direct compliance costs on Indian Tribal
governments, and is not required by stat-
ute, or preempts Tribal law, unless the
agency meets the consultation and funding
requirements of section 5 of the Executive
order. These final regulations do not have
substantial direct effects on one or more
federally recognized Indian tribes and
does not impose substantial direct compli-
ance costs on Indian Tribal governments
within the meaning of the Executive order.
VII. Congressional Review Act
Pursuant to the Congressional Review
Act (5 U.S.C. 801 et seq.), the Office of
Information and Regulatory Affairs des-
ignated this rule as not a “major rule,” as
defined by 5 U.S.C. 804(2).
Statement of Availability of IRS
Documents
IRS notices and other guidance cited in
this preamble are published in the Internal
Revenue Bulletin (or Cumulative Bulletin)
and are available from the Superintendent
of Documents, U.S. Government Publish-
ing Office, Washington, DC 20402, or by
visiting the IRS website at https://www.
irs.gov.
Drafting Information
The principal authors of these final reg-
ulations are Elizabeth Boone and Hannah
Kim, Office of the Associate Chief Coun-
sel (Income Tax & Accounting), IRS, and
John Hanebuth and Benjamin Weaver,
Office of the Associate Chief Counsel
(Passthroughs & Special Industries), IRS.
However, other personnel from the Trea-
sury Department and the IRS participated
in their development.
List of Subjects in 26 CFR Part 1
Income taxes, Reporting and record-
keeping requirements.
Amendments to the Regulations
Accordingly, 26 CFR part 1 is amended
as follows:
PART 1—INCOME TAXES
Paragraph 1. The authority citation
for part 1 is amended by adding an entry
for §1.170A-14 in numerical order, revis-
ing the entry for §1.170A-16, adding an
entry for §1.706-3 in numerical order, and
revising the entry for §1.706-4 to read as
follows:
Authority: 26 U.S.C. 7805 * * *
* * * * *
Section 1.170A-14 also issued under
26 U.S.C. 170(f)(11) and 170(h)(7).
* * * * *
Section 1.170A-16 also issued under
26 U.S.C. 170(f)(11), 170(f)(19), 170(h)
(7)(G), 6001, and 6011.
* * * * *
Section 1.706-3 also issued under 26
U.S.C. 170(h)(7)(G).
* * * * *
Section 1.706-4 also issued under 26
U.S.C. 170(h)(7)(G).
* * * * *
Par. 2. Section 1.170A-14 is amended
by revising paragraphs (a) and (j) and add-
ing paragraphs (k) through (o) to read as
follows:
§1.170A-14 Qualified conservation
contributions.
(a) Qualified conservation contribu-
tions. A deduction under section 170 of
the Internal Revenue Code (Code) is gen-
erally not allowed for a charitable con-
tribution of any interest in property that
consists of less than the donor’s entire
interest in the property other than certain
transfers in trust (see §1.170A–6 relating
to charitable contributions in trust and
§1.170A–7 relating to contributions not in
trust of partial interests in property). How-

July 22, 2024 104 Bulletin No. 2024–30
ever, a deduction may be allowed under
section 170(f)(3)(B)(iii) for the value of a
qualified conservation contribution if the
requirements of this section are met and
the contribution is not a disallowed qual-
ified conservation contribution within the
meaning of paragraph (j) of this section.
A qualified conservation contribution is
the contribution of a qualified real prop-
erty interest to a qualified organization
exclusively for conservation purposes. To
be eligible for a deduction under section
170(h) and this section, the conservation
purpose must be protected in perpetuity.
* * * * *
(j) Disallowance of certain deductions
for contributions by partnerships and
S corporations that exceed 2.5 times the
sum of the relevant bases—(1) In general.
This paragraph (j) applies the rules of sec-
tion 170(h)(7), which disallow a deduc-
tion for certain qualified conservation
contributions, as defined in section 170(h)
(1) and this section, made by, or allocated
to, partnerships or S corporations (as
defined in section 1361(a)(1) of the Code)
if the amount of the qualified conservation
contribution exceeds 2.5 times the sum of
the relevant bases as determined by this
paragraph (j) and paragraphs (k) through
(m) of this section (Disallowance Rule).
The Disallowance Rule does not apply to
qualified conservation contributions made
directly by landowners that are not pass-
through entities, such as individuals or
C corporations. See paragraph (n) of this
section for certain exceptions. See para-
graph (j)(3) of this section for definitions
of terms used in this paragraph (j) and
paragraphs (k) through (n) of this section.
(2) Application—(i) Contributing part-
nerships and contributing S corporations.
Except as provided in paragraph (n) of
this section, a qualified conservation con-
tribution by a contributing partnership or
a contributing S corporation is a disal-
lowed qualified conservation contribution
if the amount of the qualified conservation
contribution exceeds 2.5 times the sum
of each of the contributing partnership’s
or contributing S corporation’s ultimate
member’s relevant basis as determined
under this paragraph (j) and paragraphs
(k) through (m) of this section.
(ii) Upper-tier partnerships and upper-
tier S corporations. Except as provided in
paragraph (n) of this section, an allocated
portion received by an upper-tier partner-
ship or upper-tier S corporation is a disal-
lowed qualified conservation contribution
if either the contribution is a disallowed
qualified conservation contribution with
respect to the partnership that allocated
the allocated portion to the upper-tier
partnership or upper-tier S corporation, or
such allocated portion exceeds 2.5 times
the sum of each of that upper-tier part-
nership’s or upper-tier S corporation’s
ultimate member’s relevant basis as deter-
mined under this paragraph (j) and para-
graphs (k) through (m) of this section.
(iii) Partner or S corporation share-
holder claiming an inconsistent amount.
If a partner or S corporation shareholder
claims an amount of qualified conserva-
tion contribution that is inconsistent with
and greater than the partner’s distributive
share or S corporation shareholder’s pro
rata share of qualified conservation con-
tribution reported to the partner or S cor-
poration shareholder by the partnership
or S corporation, predicated on a position
that the partnership’s or S corporation’s
qualified conservation contribution was a
greater amount than the amount claimed
by the partnership or S corporation, and
the qualified conservation contribution
would have been a disallowed qualified
conservation contribution if the partner-
ship or S corporation had actually claimed
that greater amount, then the partner’s or
S corporation shareholder’s claimed qual-
ified conservation contribution is a disal-
lowed qualified conservation contribution.
(3) Definitions. The following defini-
tions apply for purposes of this paragraph
(j) and paragraphs (k) through (n) of this
section:
(i) Allocated portion. In the case of an
upper-tier partnership or upper-tier S cor-
poration that receives, directly or indi-
rectly, a distributive share of a qualified
conservation contribution, the phrase allo-
cated portion means the amount of such
distributive share.
(ii) Amount of qualified conservation
contribution. The amount of a contribut-
ing partnership’s or contributing S corpo-
ration’s qualified conservation contribu-
tion is the amount claimed as a qualified
conservation contribution on the return of
the contributing partnership or contrib-
uting S corporation for the taxable year
in which the contribution is made. If the
contributing partnership or contributing
S corporation files an amended return or
administrative adjustment request under
section 6227 of the Code claiming a higher
amount with respect to the qualified con-
servation contribution, the rules of this
section must be re-applied with respect
to such higher amount to determine the
application of section 170(h)(7) and this
section; for example, if a contributing
S corporation’s original return claims a
qualified conservation contribution that
does not exceed 2.5 times the sum of the
relevant bases, and the S corporation sub-
sequently files an amended return claim-
ing a higher amount with respect to the
qualified conservation contribution that
does exceed 2.5 times the sum of the rel-
evant bases, then the entire amount of the
qualified conservation contribution is a
disallowed qualified conservation con-
tribution (unless one of the exceptions
in paragraph (n) of this section applies).
If the contributing partnership or con-
tributing S corporation files an amended
return or timely administrative adjustment
request under section 6227 claiming a
lower amount with respect to the qualified
conservation contribution, the rules of this
section will be re-applied with respect to
such lower amount to determine the appli-
cation of section 170(h)(7) and this sec-
tion if and only if the amended return or
timely administrative adjustment request
is filed before the contributing partnership
or contributing S corporation is put on
notice of an IRS examination with respect
to the qualified conservation contribution.
A contributing partnership or contributing
S corporation is considered to be on notice
after the earlier of—
(A) The date the contributing partner-
ship or contributing S corporation is first
contacted by the Internal Revenue Service
in connection with any examination of a
return that relates to the qualified conser-
vation contribution; or
(B) The date any person is first con-
tacted by the Internal Revenue Service
concerning an examination of that person
under section 6700 (relating to the penalty
for promoting abusive tax shelters) for an
activity that relates to the qualified conser-
vation contribution.
(iii) Contributing partnership. The
term contributing partnership means a

Bulletin No. 2024–30 105 July 22, 2024
partnership that makes a qualified conser-
vation contribution.
(iv) Contributing S corporation. The
term contributing S corporation means an
S corporation that makes a qualified con-
servation contribution.
(v) Direct interest. The term direct
interest refers to an ownership interest
in a contributing partnership, upper-tier
partnership, contributing S corporation,
or upper-tier S corporation that is held
directly, or through an entity disregarded
as separate from its owner for Federal
income tax purposes, a qualified sub-
chapter S subsidiary as defined in section
1361(b)(3), or through a grantor trust
(under subpart E of part 1 of subchapter J
of chapter 1 of the Code). In the case of a
partner that is a C corporation (as defined
in section 1361(a)(2)), non-grantor trust,
or an estate, or an S corporation share-
holder that is a non-grantor trust or an
estate, the direct interest in the partnership
or S corporation, as applicable, is held by
the C corporation, non-grantor trust, or
estate; the C corporation’s shareholders,
trust beneficiaries, and estate beneficia-
ries are not considered to hold any inter-
est in the partnership or S corporation, as
applicable, for purposes of this paragraph
(j) and paragraphs (k) through (n) of this
section.
(vi) Directly. An ownership interest
is held directly if it is not held through
one or more upper-tier partnerships or
upper-tier S corporations. A distribu-
tive share or pro rata share of a qualified
conservation contribution is received
directly if it does not pass through
one or more upper-tier partnerships or
upper-tier S corporations.
(vii) Disallowed qualified conservation
contribution. The term disallowed qual-
ified conservation contribution means
a qualified conservation contribution or
allocated portion for which no deduction
is allowed pursuant to section 170(h)(7)
and this paragraph (j).
(viii) Indirect interest. The term indi-
rect interest refers to an ownership interest
in a contributing partnership, contributing
S corporation, upper-tier partnership, or
upper-tier S corporation held through an
upper-tier S corporation or one or more
upper-tier partnerships.
(ix) Indirectly. An ownership interest is
held indirectly if it is held through one or
more upper-tier partnerships or upper-tier
S corporations. A distributive share or pro
rata share of a qualified conservation con-
tribution is received indirectly if it passes
through one or more upper-tier partner-
ships or upper-tier S corporations.
(x) Ultimate member. The term ulti-
mate member means, with respect to any
partnership or S corporation, any partner
(that is not itself a partnership or S corpo-
ration) or S corporation shareholder that
receives a distributive share or pro rata
share, directly or indirectly, of a qualified
conservation contribution. Thus, ultimate
members will either be partners holding
a direct interest in a partnership, which
may be the contributing partnership or
an upper-tier partnership, or shareholders
holding a direct interest in an S corpo-
ration, which may be the contributing S
corporation or an upper-tier S corporation.
Upper-tier S corporations and upper-tier
partnerships themselves are not consid-
ered ultimate members.
(xi) Upper-tier partnership. The term
upper-tier partnership means a partner-
ship that receives an allocated portion.
(xii) Upper-tier S corporation. The
term upper-tier S corporation means an
S corporation that receives an allocated
portion.
(4) Effect of Disallowance Rule—(i)
If the Disallowance Rule applies to a
contributing partnership or contributing
S corporation. If a contributing partner-
ship’s or contributing S corporation’s
qualified conservation contribution is a
disallowed qualified conservation contri-
bution under this paragraph (j), then:
(A) Any upper-tier partnership’s or
upper-tier S corporation’s allocated por-
tion of such contribution is a disallowed
qualified conservation contribution,
regardless of whether such allocated por-
tion exceeds 2.5 times the sum of each of
the upper-tier partnership’s or upper-tier
S corporation’s ultimate member’s rele-
vant basis; and
(B) No person (whether holding a
direct or indirect interest in such contrib-
uting partnership or contributing S cor-
poration) may claim a deduction under
any provision of the Code with respect to
any amount of such disallowed qualified
conservation contribution, regardless of
whether that person’s distributive share
or pro rata share of the disallowed quali-
fied conservation contribution exceeds 2.5
times its relevant basis.
(ii) If the Disallowance Rule does
not apply to a contributing partnership
or contributing S corporation. If a con-
tributing partnership’s or contributing
S corporation’s qualified conservation
contribution is not a disallowed qualified
conservation contribution under this para-
graph (j), then:
(A) The distributive share or pro rata
share of any ultimate member holding a
direct interest in the contributing partner-
ship or contributing S corporation is not a
disallowed qualified conservation contri-
bution; and
(B) Any upper-tier partnership or
upper-tier S corporation that receives an
allocated portion of such qualified conser-
vation contribution must separately apply
the rules of section 170(h)(7) and this
paragraph (j) and paragraphs (k) through
(m) of this section to determine whether
that upper-tier partnership’s or upper-tier
S corporation’s allocated portion is a dis-
allowed qualified conservation contribu-
tion.
(iii) If the Disallowance Rule applies
to an upper-tier partnership or an upper-
tier S corporation. If an upper-tier part-
nership’s or upper-tier S corporation’s
allocated portion is a disallowed qualified
conservation contribution under this para-
graph (j), then:
(A) Any subsequent upper-tier part-
nership’s or upper-tier S corporation’s
allocated portion of such allocated por-
tion is a disallowed qualified conserva-
tion contribution, regardless of whether
the subsequent upper-tier partnership’s or
upper-tier S corporation’s allocated por-
tion exceeds 2.5 times the sum of each of
the subsequent upper-tier partnership’s or
upper-tier S corporation’s ultimate mem-
ber’s relevant basis; and
(B) No person holding a direct or indi-
rect interest in that upper-tier partnership
or upper-tier S corporation may claim a
deduction under any provision of the Code
with respect to any amount of that upper-
tier partnership’s or upper-tier S corpo-
ration’s allocated portion, regardless of
whether that person’s distributive share
or pro rata share of the allocated portion
exceeds 2.5 times its relevant basis. How-
ever, this does not affect the application
of this paragraph (j) and paragraphs (k)

July 22, 2024 106 Bulletin No. 2024–30
through (m) of this section to another
partner of the contributing partnership;
for example, if the qualified conservation
contribution is not a disallowed qualified
conservation contribution with respect to
the contributing partnership, then the dis-
tributive share of such contribution of an
ultimate member holding a direct interest
in the contributing partnership is not a
disallowed qualified conservation contri-
bution, notwithstanding that the qualified
conservation contribution is a disallowed
qualified conservation contribution with
respect to one or more upper-tier partner-
ships or upper-tier S corporations.
(iv) If the Disallowance Rule does
not apply to an upper-tier partnership or
upper-tier S corporation. If an upper-tier
partnership’s or upper-tier S corporation’s
allocated portion is not a disallowed qual-
ified conservation contribution under this
paragraph (j), then:
(A) The distributive share or pro rata
share of such allocated portion of any
ultimate member holding a direct interest
in the upper-tier partnership or upper-tier
S corporation is not a disallowed qualified
conservation contribution; and
(B) Any subsequent upper-tier part-
nership or upper-tier S corporation that
receives an allocated portion of such allo-
cated portion must separately apply the
rules of section 170(h)(7) and this para-
graph (j) and paragraphs (k) through (m)
of this section to determine whether that
subsequent upper-tier partnership’s or
upper-tier S corporation’s allocated por-
tion is treated as a disallowed qualified
conservation contribution.
(5) No inference. There is no presump-
tion that a qualified conservation contri-
bution that is not a disallowed qualified
conservation contribution as defined in
paragraph (j)(3)(vii) of this section is com-
pliant with section 170, any other section
of the Code, the regulations, or any other
guidance. Compliance with section 170(h)
(7) and this paragraph (j) and paragraphs
(k) through (n) of this section is not a safe
harbor for purposes of any other provi-
sion of law or with respect to the value
of the contribution. Such transactions are
subject to adjustment or disallowance for
any other reason, including failure to sat-
isfy the other requirements of section 170
or overvaluation of the contribution. In
addition, taxpayers who engage in such
transactions may be required to disclose
under §1.6011-4 the transactions as listed
transactions.
(6) Examples. The following examples
illustrate the rules of this paragraph (j).
For these three examples in this paragraph
(j)(6), assume that the partnership alloca-
tions comply with the rules of subchapter
K of chapter 1 of the Code, and that the
exceptions in paragraph (n) of this section
do not apply.
(i) Example 1: Disallowed qualified conservation
contribution—(A) Facts. A, an individual, and B, a
C corporation, form AB Partnership, a partnership
for Federal income tax purposes. AB Partnership
acquires real property. Two years later, AB Partner-
ship makes a qualified conservation contribution
with respect to the property and claims a contribution
of $100X on its return. AB Partnership allocates the
contribution equally to A and B. A’s relevant basis is
$30X, and B’s relevant basis is $8X.
(B) Analysis. A and B are the ultimate members
of AB Partnership because they each receive a dis-
tributive share of the qualified conservation contribu-
tion and are not partnerships or S corporations. The
claimed amount of AB Partnership’s qualified con-
servation contribution is $100X, which exceeds 2.5
times the sum of A’s and B’s relevant bases, which is
$95X ($95X = 2.5 x (A’s $30X relevant basis + B’s
$8X relevant basis)). Therefore, AB Partnership’s
contribution is a disallowed qualified conservation
contribution. No person may claim any deduction
with respect to this contribution, even though A’s
$50X distributive share of the contribution does not
exceed 2.5 times A’s $30X relevant basis.
(ii) Example 2: Not a disallowed qualified con-
servation contribution—(A) Facts. Individuals C
and D form CD Partnership, a partnership for Fed-
eral income tax purposes. CD Partnership acquires
real property. Two years later, CD Partnership makes
a qualified conservation contribution with respect to
the property and claims a contribution of $100X on
its return. CD Partnership allocates the contribution
$5X to C and $95X to D. C’s relevant basis is $6X,
and D’s relevant basis is $34X.
(B) Analysis. C and D are the ultimate mem-
bers of CD Partnership because they each receive
a distributive share of the qualified conservation
contribution and are not partnerships or S corpo-
rations. The claimed amount of CD Partnership’s
qualified conservation contribution is $100X, which
does not exceed 2.5 times the sum of C’s and D’s
relevant bases, which is also $100X ($100X = 2.5 x
(C’s $6X relevant basis + D’s $34X relevant basis)).
Therefore, CD Partnership’s contribution is not a
disallowed qualified conservation contribution (that
is, not disallowed by section 170(h)(7) and this para-
graph (j)) with respect to CD Partnership, C, or D,
even though D’s $95X distributive share of the con-
tribution exceeds 2.5 times D’s $34X relevant basis.
(iii) Example 3: Tiered partnerships—(A) Facts.
Individuals E and F form UTP Partnership, a partner-
ship for Federal income tax purposes. UTP Partner-
ship and G, a C corporation, form LTP Partnership,
a partnership for Federal income tax purposes. LTP
Partnership acquires real property. Two years later,
LTP Partnership makes a qualified conservation con-
tribution with respect to the property and claims a
contribution of $100X on its return. LTP Partnership
allocates the contribution $5X to G and $95X to UTP
Partnership. UTP Partnership allocates its $95X por-
tion of the contribution $45X to E and $50X to F. G’s
relevant basis is $10X, E’s relevant basis is $11X,
and F’s relevant basis is $21X.
(B) Analysis for LTP Partnership. The ultimate
members of LTP Partnership are G, E, and F because
they each receive a distributive share of the qualified
conservation contribution and are not a partnership
or S corporation. Because UTP Partnership is a part-
nership, it is not an ultimate member of LTP Partner-
ship, even though it receives a distributive share of
the qualified conservation contribution. The amount
of LTP Partnership’s qualified conservation contribu-
tion is $100X, which does not exceed 2.5 times the
sum of each of the ultimate member’s relevant basis,
which is $105X ($105X = 2.5 x (G’s $10X relevant
basis + E’s $11X relevant basis + F’s $21X relevant
basis)). Therefore, LTP Partnership’s contribution is
not a disallowed qualified conservation contribution
(that is, is not disallowed by section 170(h)(7) and
this paragraph (j)) with respect to LTP Partnership
and G.
(C) Analysis for UTP Partnership. Because UTP
Partnership receives an allocated portion, UTP Part-
nership must apply this paragraph (j) and paragraphs
(k) through (m) of this section to determine whether
its allocated portion is a disallowed qualified conser-
vation contribution. The ultimate members of UTP
Partnership are E and F because they each receive
a distributive share of UTP Partnership’s allocated
portion and are not partnerships or S corporations.
The amount of UTP Partnership’s allocated portion
of LTP Partnership’s qualified conservation contribu-
tion is $95X, which exceeds 2.5 times the sum of E’s
and F’s relevant bases, which is $80X ($80X = 2.5 x
(E’s $11X relevant basis + F’s $21X relevant basis)).
Therefore, UTP Partnership’s allocated portion of
LTP Partnership’s contribution is a disallowed qual-
ified conservation contribution with respect to UTP
Partnership, E, and F. No partner of UTP Partnership
may claim any deduction with respect to this contri-
bution, even though F’s $50X distributive share of
the contribution does not exceed 2.5 times F’s $21X
relevant basis. This does not affect the determination
that G’s distributive share of the contribution is not a
disallowed qualified conservation contribution.
(k) Determination of relevant basis.
For purposes of this section, the term rele-
vant basis means, with respect to any ulti-
mate member, the portion of such ultimate
member’s modified basis (as determined
under paragraph (l) of this section) that is
allocable (under the rules of paragraph (m)
of this section) to the portion of the real
property with respect to which the quali-
fied conservation contribution is made.
(l) Determination of modified basis—
(1) In general. In the case of an ultimate
member holding a direct interest in a part-
nership, the ultimate member’s modified
basis is determined by such partnership

Bulletin No. 2024–30 107 July 22, 2024
immediately before the qualified conser-
vation contribution is made in the man-
ner described in paragraph (l)(2) of this
section. In the case of an ultimate mem-
ber holding a direct interest in an S cor-
poration, the ultimate member’s modified
basis is determined by such S corporation
in the manner described in paragraph (l)
(3) of this section.
(2) Partners in partnerships—(i) Com-
putation. For purposes of this section, the
term modified basis means, with respect to
any ultimate member that is a direct part-
ner in either a contributing partnership or
an upper-tier partnership, such ultimate
member’s adjusted basis in its interest
in the partnership in which the ultimate
member holds a direct interest as of the
beginning of the first day of the partner-
ship’s taxable year in which the qualified
conservation contribution is made, with
adjustments as determined under para-
graphs (l)(2)(ii) through (vi) of this sec-
tion. However, if the ultimate member
was not a partner as of the beginning of
the first day of the partnership’s taxable
year in which the qualified conservation
contribution is made, then the term mod-
ified basis means such ultimate member’s
adjusted basis in its interest in the partner-
ship immediately after the transaction that
resulted in the ultimate member becoming
a partner, with adjustments as determined
under paragraphs (l)(2)(ii) through (vi)
of this section. The adjustments under
paragraphs (l)(2)(ii) through (vi) must be
made in the order in which they are listed.
(ii) Step 1. First, the computation of
modified basis must start with the ultimate
member’s adjusted basis under paragraph
(l)(2)(i) of this section and then reflect an
increase for any contributions made by the
ultimate member to the partnership during
the portion of the year commencing with
the beginning of the taxable year of the
partnership and ending immediately prior
to the time of day at which the qualified
conservation contribution is made as pro-
vided in section 722 of the Code.
(iii) Step 2. Second, if between the
beginning of the partnership’s taxable
year and the time of day at which the qual-
ified conservation contribution is made,
the ultimate member acquired additional
interests in the partnership, the amount
determined under paragraph (l)(2)(ii) of
this section must be increased by the ulti-
mate member’s initial basis in those addi-
tional interests. If, between the beginning
of the partnership’s taxable year and the
time of day at which the qualified conser-
vation contribution is made, the ultimate
member partially disposed of its interest
in the partnership, the amount determined
under paragraph (l)(2)(ii) of this section
must be decreased by the ultimate mem-
ber’s basis in the interests disposed of.
(iv) Step 3. Third, the amount deter-
mined under paragraph (l)(2)(iii) of this
section must be adjusted, as provided in
section 705 of the Code, by the ultimate
member’s hypothetical distributive share
of partnership items attributable to the
portion of the year commencing with the
beginning of the taxable year of the part-
nership and ending immediately prior to
the time of day at which the qualified con-
servation contribution is made. In making
this determination, the partnership must
apply the rules of §1.706-4 and apply a
hypothetical interim closing method to
allocate the partnership’s items attribut-
able to the portion of the year commenc-
ing with the beginning of the taxable year
of the partnership and ending immediately
prior to the time of day at which the qual-
ified conservation contribution is made.
The partnership cannot apply any con-
vention in §1.706-4(c) to the hypothetical
determination of the partners’ distribu-
tive shares, but rather must perform the
calculation as though the determination
occurred immediately prior to the time of
day at which the qualified conservation
contribution is made. This hypothetical
determination of the partners’ distribu-
tive shares is only for purposes of calcu-
lating modified basis. This paragraph (l)
does not require the partnership to use
the interim closing method with respect
to the determination of its partners’ actual
distributive shares of partnership items of
income, gain, loss, deduction, and credit
for the taxable year in which the qualified
conservation contribution is made or oth-
erwise. See §1.706-4 for applicable rules
for the determination of a partner’s dis-
tributive share when a partner’s interest
varies during a partnership taxable year.
(v) Step 4. Fourth, the amount deter-
mined under paragraph (l)(2)(iv) of this
section must be reduced (but not below
zero) by any distributions made by the
partnership to the ultimate member during
the portion of the year commencing with
the beginning of the taxable year of the
partnership and ending immediately prior
to the time of day at which the qualified
conservation contribution is made as pro-
vided in section 733 of the Code.
(vi) Step 5. Fifth, the amount deter-
mined under paragraph (l)(2)(v) of this
section must be reduced by the full
amount of the ultimate member’s share
of §1.752-1 liabilities of any partnership
(including a lower-tier partnership). The
remaining amount is such ultimate mem-
ber’s modified basis. Thus, an ultimate
member’s modified basis may be less than
zero.
(3) S corporation shareholder—(i)
Computation. For purposes of this sec-
tion, the term modified basis means, with
respect to any ultimate member that is
a shareholder of either a contributing S
corporation or an upper-tier S corpora-
tion, such ultimate member’s adjusted
basis in its shares in the S corporation as
of the end of the S corporation’s taxable
year in which the qualified conservation
contribution is made, with adjustments
as determined under paragraphs (l)(3)(ii)
and (iii) of this section. However, if the
ultimate member was not a shareholder
at the end of the S corporation’s taxable
year in which the qualified conservation
contribution is made, then the term mod-
ified basis means such ultimate member’s
adjusted basis in its shares in the S corpo-
ration immediately prior to the transaction
that terminated its interest in the S cor-
poration, with adjustments as determined
under paragraphs (l)(3)(ii) and (iii) of this
section. Modified basis does not include
the ultimate member’s adjusted basis in
any indebtedness of the S corporation to
the ultimate member. The adjustments
under paragraphs (l)(3)(ii) and (iii) of
this section must be made in the order in
which they are listed.
(ii) Step 1. First, the computation of
modified basis must start with the ultimate
member’s adjusted basis under paragraph
(l)(3)(i) of this section, and then reflect an
increase for the extent to which the ulti-
mate member’s adjusted basis reflects a
reduction as a result of the qualified con-
servation contribution. Thus, the ultimate
member’s modified basis with respect to
a qualified conservation contribution does
not reflect any reduction for the ultimate

July 22, 2024 108 Bulletin No. 2024–30
member’s pro rata share of the S corpora-
tion’s basis in the conservation easement
or other property contributed in the quali-
fied conservation contribution.
(iii) Step 2. Second, the amount deter-
mined under paragraph (l)(3)(ii) of this
section must be multiplied by the number
of days during the S corporation’s taxable
year in which the ultimate member was a
shareholder and divided by the total num-
ber of days during the S corporation’s
taxable year. The resulting amount is such
ultimate member’s modified basis.
(4) Examples. The following examples
illustrate the provisions of this paragraph
(l). For the four examples in this para-
graph (l)(4), assume that the partnership
allocations comply with the rules of sub-
chapter K of chapter 1 of the Code and the
exceptions in paragraph (n) of this section
do not apply.
(i) Example 1—(A) Facts. AB Partnership is a
calendar-year partnership for Federal income tax
purposes whose partners are A and B, each of whom
is an individual and has a 50 percent interest in
income, gain, loss, and deduction. Several years ago,
B contributed property to AB Partnership subject to
a §1.752-1 liability. At the beginning of AB Partner-
ship’s 2024 taxable year (the beginning of the day
on January 1, 2024), A’s adjusted basis in its interest
in AB Partnership is $19X, and B’s adjusted basis
in its interest in AB Partnership is $17X. At 10:01
a.m. on August 29, 2024, AB Partnership makes a
qualified conservation contribution. On August 29,
2024, the amount of the §1.752-1 liability is $10X
and is allocated under the rules of section 752 to A.
During 2024, there were no variations in any part-
ner’s interests in AB Partnership within the meaning
of section 706. During 2024, AB Partnership earned
$8X of ordinary income and sustained ($4X) of capi-
tal loss in the ordinary course of its business, both of
which are allocated equally to A and B. Within 2024,
AB Partnership earned $6X of ordinary income, and
sustained ($4X) of capital loss between the begin-
ning of the day on January 1, 2024, and 10:00 a.m.
on August 29, 2024, and AB Partnership earned $2X
of ordinary income, and sustained $0X of capital
loss between 10:01 a.m. on August 29, 2024, and the
end of the day on December 31, 2024. Other than
the qualified conservation contribution, none of AB
Partnership’s items are extraordinary items within
the meaning of §1.706-4(e)(2). In April 2024, AB
Partnership distributed $1X cash to A. In November
2024, B contributed $2X cash to AB Partnership.
(B) Analysis. The ultimate members of AB Part-
nership are A and B because they each receive a
distributive share of the qualified conservation con-
tribution and are not partnerships or S corporations.
To determine A’s and B’s modified bases, AB Part-
nership must start with A’s and B’s adjusted bases
in AB Partnership as of the beginning of the first
day of the taxable year of AB Partnership and then
make the adjustments required under paragraphs
(l)(2)(ii) through (vi) of this section. Accordingly,
the computation of A’s beginning modified basis
begins with $19X, and the computation of B’s mod-
ified basis begins with $17X. First, those amounts
must be increased by any contributions between the
beginning of the day on January 1, 2024, and 10
a.m. on August 29, 2024. Because there were none,
after this step, the computation of A’s modified basis
remains at $19X and the computation of B’s mod-
ified basis remains at $17X. Next, these amounts
must be adjusted for any additional acquisitions of
partnership interests by an existing partner or partial
dispositions of partnership interests by a continuing
partner between the beginning of the partnership’s
taxable year and the time of day at which the qual-
ified conservation contribution is made. Because
there were none, after this step, the computation of
A’s modified basis remains at $19X and the compu-
tation of B’s modified basis remains at $17X. Then
these amounts must be adjusted as provided in sec-
tion 705 by A’s and B’s hypothetical distributive
shares of AB Partnership’s items attributable to the
portion of the year between the beginning of the day
on January 1, 2024, and 10:00 a.m. on August 29,
2024. Thus, the computations of A’s and B’s mod-
ified bases will each reflect an increase for their
hypothetical $3X distributive share of the $6X ordi-
nary income that AB Partnership earned between the
beginning of the day on January 1, 2024, and 10:00
a.m. on August 29, 2024, and a decrease for their
hypothetical ($2X) distributive share of the ($4X)
capital loss that AB Partnership incurred between the
beginning of the day on January 1, 2024, and 10:00
a.m. on August 29, 2024. Therefore, after this step,
the computation of A’s modified basis reflects an
increase from $19X to $20X, and the computation of
B’s modified basis reflects an increase from $17X to
$18X. Next, these amounts must be reduced by any
distributions between the beginning of the day on
January 1, 2024, and 10:00 a.m. on August 29, 2024.
Thus, the computation of A’s modified basis reflects
a reduction from $20X to $19X. B did not receive
any distribution, so the computation of B’s modified
basis remains at $18X. Finally, the full amount of A’s
and B’s shares of §1.752-1 liabilities must be sub-
tracted. Thus, the computation of A’s modified basis
reflects a reduction from $19X to $9X, which is A’s
modified basis. B’s modified basis is $18X.
(ii) Example 2—(A) Facts. CD Partnership, a
partnership for Federal income tax purposes, is a
calendar-year partnership using the calendar day
convention under §1.706-4 whose partners on Jan-
uary 1, 2024, are C and D, each of whom is an indi-
vidual and has a 50 percent interest in income, gain,
loss, and deduction. On March 15, 2024, C sells its
interest to E, a C corporation. At 1:15 p.m. on Sep-
tember 15, 2024, CD Partnership makes a qualified
conservation contribution. On September 21, 2024,
D sells its interest to F, an individual. During 2024,
CD Partnership earned $8X of ordinary income and
sustained ($14X) of ordinary loss. Within 2024, CD
Partnership earned all $8X of ordinary income in
November and December, and sustained all ($14X)
of ordinary loss in April through August. In May
2024, D contributed $6X cash to CD Partnership,
and E contributed property with a fair market value
of $6X and basis of $3X. D and E are equal partners
during the period in which they are both partners. CD
Partnership made no distributions during 2024. CD
Partnership had no §1.752-1 liabilities during 2024.
In accordance with §1.706-4(e)(2)(xiii), CD Partner-
ship treats its qualified conservation contribution as
an extraordinary item allocable only to D and E, its
partners at 1:15 p.m. on September 15, 2024. Other
than the qualified conservation contribution, none
of AB Partnership’s items are extraordinary items
within the meaning of §1.706-4(e)(2). CD Partner-
ship uses the proration method under §1.706-4 to
allocate its items among C, D, E, and F. Under the
proration method, CD Partnership allocates each C,
D, E, and F a distributive share of a portion of both
the $8X ordinary income and the ($14X) ordinary
loss. D’s adjusted basis in its interest in CD Part-
nership at the beginning of CD Partnership’s 2024
taxable year (the beginning of the day on January 1,
2024) is $8X. E’s adjusted basis in its interest in CD
Partnership immediately after E acquires C’s interest
in CD Partnership is $6X.
(B) Analysis. The ultimate members of CD
Partnership are D and E because they each receive
a distributive share of the qualified conservation
contribution and are not partnerships or S corpo-
rations. To determine D’s and E’s modified bases,
CD Partnership must start with D’s and E’s adjusted
bases in CD Partnership as of the beginning of the
day on January 1, 2024, and then make the adjust-
ments required under paragraphs (l)(2)(ii) through
(vi) of this section. However, because E was not a
partner as of the beginning of the day on January 1,
2024, CD Partnership must start with E’s adjusted
basis immediately after E’s purchase of C’s interest
in CD Partnership. Accordingly, the computation of
D’s modified basis begins with $8X, and the compu-
tation of E’s modified basis begins with $6X. Then,
these amounts must be increased by any contribu-
tions made by D or E, respectively, to CD Partner-
ship between the beginning of the day on January 1,
2024, and 1:14 p.m. on September 15, 2024. There-
fore, the computation of D’s modified basis reflects
an increase from $8X to $14X (for D’s $6X contri-
bution of cash to CD Partnership in May 2024), and
the computation of E’s modified basis reflects an
increase from $6X to $9X (for E’s contribution of
property to CD Partnership with a basis of $3X in
May 2024). Next, these amounts must be adjusted
for any additional acquisitions of partnership inter-
ests by an existing partner or partial dispositions of
partnership interests by a continuing partner between
the beginning of the partnership’s taxable year and
the time of day at which the qualified conservation
contribution is made. Because there were none, after
this step, the computation of D’s modified basis
remains at $14X and the computation of E’s modi-
fied basis remains at $9X. Next, these amounts must
be adjusted as provided in section 705 by D’s and E’s
hypothetical distributive shares of CD Partnership’s
items attributable to the portion of the year between
the beginning of the day on January 1, 2024, and
1:14 p.m. on September 15, 2024. CD Partnership
must perform the analysis using an interim closing
method to a hypothetical variation at 1:14 p.m. on
September 15, 2024, immediately prior to the qual-
ified conservation contribution. The computation
of D’s modified basis will reflect an adjustment for
its hypothetical distributive share of all CD Part-
nership’s items incurred from the beginning of the
day on January 1, 2024, through 1:14 p.m. on Sep-

Bulletin No. 2024–30 109 July 22, 2024
tember 15, 2024. The computation of E’s modified
basis will reflect an adjustment for its hypothetical
distributive share of all CD Partnership’s items
incurred from the end of the day on March 15, 2024,
through 1:14 p.m. on September 15, 2024. For pur-
poses of this paragraph (l)(4)(ii)(B) (Example 2), it
does not matter that CD Partnership actually used
the proration method to allocate its 2024 income.
Instead, under this hypothetical calculation of the
distributive shares, the computation of D’s and E’s
modified bases will each reflect a reduction for
their 50 percent share of the ($14X) ordinary loss.
Because none of CD Partnership’s $8X of ordinary
income was earned between the beginning of the
day on January 1, 2024, and 1:14 p.m. on Septem-
ber 15, 2024, neither D’s nor E’s modified basis will
reflect an increase for any amount of that income.
Thus, after this step, the computation of D’s modified
basis reflects a reduction from $14X to $7X, and the
computation of E’s modified basis reflects a reduc-
tion from $9X to $2X. Then, these amounts must be
reduced by any distributions between the beginning
of the day on January 1, 2024, and 1:14 p.m. on Sep-
tember 15, 2024. Because there were none, after this
step, the computation of D’s modified basis remains
at $7X, and the computation of E’s modified basis
remains at $2X. Finally, the full amount of D’s and
E’s shares of §1.752-1 liabilities must be subtracted.
Because there were none, D’s modified basis is $7X,
and E’s modified basis is $2X.
(iii) Example 3—(A) Facts. HI Inc. is a calen-
dar-year S corporation whose shareholders on Jan-
uary 1, 2024, are H and I, each of whom owns 50
percent of the shares. On May 1, 2024, H sells all
of its stock to J. In June 2024, HI Inc. contributes a
conservation easement that is a qualified conserva-
tion contribution on 400 acres of real property. HI
Inc.’s adjusted basis in the conservation easement
is $12X (which is different from HI Inc.’s adjusted
basis in the 400 acres and also may be different from
the value of the conservation easement). On July 1,
2024, I sells all of its stock to K. Under §1.1377-1,
HI Inc. allocates its qualified conservation contribu-
tion 1/6 to H, 1/4 to I, 1/3 to J, and 1/4 to K. Pursuant
to the second sentence of section 1367(a)(2)(B), as
a result of the qualified conservation contribution,
H’s adjusted basis in its shares is reduced by $2X,
I’s adjusted basis in its shares is reduced by $3X, J’s
adjusted basis in its shares is reduced by $4X, and
K’s adjusted basis in its shares is reduced by $3X.
At the end of HI Inc.’s 2024 taxable year (the end of
the day on December 31, 2024), J’s adjusted basis
in its shares is $15X and K’s adjusted basis in its
shares is $11X. Immediately prior to H’s sale to J,
H’s adjusted basis in its shares was $8X. Immedi-
ately prior to I’s sale to K, I’s adjusted basis in its
shares was $7X. Whether H, I, J, or K have adjusted
basis in indebtedness of HI Inc., has no effect on the
computation of their modified bases. H is an estate of
a deceased shareholder, and I, J, and K are individu-
als that are not nonresident aliens.
(B) Analysis. The ultimate members of HI Inc.
are H, I, J, and K, because they each receive a pro
rata share of the qualified conservation contribution
and are not partnerships or S corporations. To deter-
mine H’s, I’s, J’s, and K’s modified bases, HI Inc.
must begin with each shareholder’s adjusted basis in
its shares as of the end of the day on December 31,
2024 (the end of the S corporation’s taxable year in
which it made the qualified conservation contribu-
tion). However, because H and I were not sharehold-
ers as of the end of the day on December 31, 2024,
HI Inc. must begin with H’s adjusted basis imme-
diately before H’s sale to J, and I’s adjusted basis
immediately before I’s sale to K. Accordingly, the
computation of H’s modified basis begins with $8X,
the computation of I’s modified basis begins with
$7X, the computation of J’s modified basis begins
with $15X, and the computation of K’s modified
basis begins with $11X. Next, HI Inc. must increase
these amounts by the extent the adjusted bases were
reduced as a result of the qualified conservation con-
tribution. Accordingly, the computation of H’s modi-
fied basis reflects an increase from $8X to $10X, the
computation of I’s modified basis reflects an increase
from $7X to $10X, the computation of J’s modified
basis reflects an increase from $15X to $19X, and
the computation of K’s modified basis reflects an
increase from $11X to $14X. Finally, HI Inc. must
multiply each of these amounts by the number of
days during 2024 in which each ultimate member
was a shareholder, and divide by 366 (the total num-
ber of days in HI Inc.’s 2024 taxable year). H was a
shareholder for 122 days. Thus, H’s modified basis
is $3.33X ($10X x 122/366). I was a shareholder for
183 days. Thus, I’s modified basis is $5X ($10X x
183/366). J was a shareholder for 244 days. Thus, J’s
modified basis is $12.67X ($19X x 244/366). K was
a shareholder for 183 days. Thus, K’s modified basis
is $7X ($14X x 183/366).
(iv) Example 4—(A) Facts. PQ Partnership is
a calendar-year partnership for Federal income tax
purposes whose partners are individuals P and Q. At
the beginning of PQ Partnership’s 2024 taxable year
(the beginning of the day on January 1, 2024), P has a
sixty percent interest in all of PQ Partnership’s items,
including items of income, gain, loss, deduction,
credit, and charitable contributions, and P’s adjusted
basis in its interest in PQ Partnership is $60X. At the
beginning of PQ Partnership’s 2024 taxable year,
Q has a forty percent interest in all of PQ Partner-
ship’s items, including items of income, gain, loss,
deduction, credit, and charitable contributions, and
Q’s adjusted basis in its interest in PQ Partnership is
$30X. On March 15, 2024, P sells two-thirds of P’s
interest in PQ Partnership to individual Z, who was
not previously a partner in PQ Partnership, for $55X.
At the time of the sale, P’s adjusted basis in the part-
nership interests P sold to Z was $40X. At noon on
August 29, 2024, PQ Partnership makes a qualified
conservation contribution. PQ Partnership allocates
twenty percent of the qualified conservation contri-
bution to P, forty percent to Q, and forty percent to Z.
Between January 1 and August 29, 2024, PQ Partner-
ship had no items of income, gain, loss, or deduction,
and did not make any distributions. No partner made
any contributions during 2024. PQ Partnership did
not have any §1.752-1 liabilities during 2024.
(B) Analysis. P, Q, and Z are the ultimate mem-
bers of PQ Partnership because they each receive a
distributive share of the qualified conservation con-
tribution and are not partnerships or S corporations.
To determine P’s, Q’s, and Z’s modified bases, PQ
Partnership must start with P’s, Q’s, and Z’s adjusted
bases in PQ Partnership as of the beginning of the
first day of the taxable year of PQ Partnership and
then make the adjustments required under para-
graphs (l)(2)(ii) through (vi) of this section. How-
ever, because Z was not a partner as of the beginning
of the day on January 1, 2024, PQ Partnership must
start with Z’s adjusted basis immediately after Z’s
purchase of two-thirds of P’s interest in PQ Partner-
ship. Accordingly, the computation of P’s modified
basis begins with $60X, the computation of Q’s
modified basis begins with $30X, and the computa-
tion of Z’s modified basis begins with $55X. First,
those amounts must be increased by any contribu-
tions between the beginning of the day on January 1,
2024, and noon on August 29, 2024. Because there
were none, after this step, the computation of P’s
modified basis remains at $60X, the computation of
Q’s modified basis remains at $30X, and the compu-
tation of Z’s modified basis remains at $55X. Next,
these amounts must be adjusted for any additional
acquisitions of partnership interests by an existing
partner or partial dispositions of partnership inter-
ests by a continuing partner between the beginning
of the partnership’s taxable year and the time of day
at which the qualified conservation contribution is
made. P sold two-thirds of its interest to Z prior to
PQ Partnership’s qualified conservation contribu-
tion; P’s basis in the interests it sold was $40X. As a
result, the computation of P’s modified basis reflects
a reduction from $60X to $20X. Then these amounts
must be adjusted as provided in section 705 by P’s,
Q’s, and Z’s hypothetical distributive shares of PQ
Partnership’s items attributable to the portion of the
year between the beginning of the day on January 1,
2024, and noon on August 29, 2024. Because there
were none, after this step, the computation of P’s
modified basis remains at $20X, the computation of
Q’s modified basis remains at $30X, and the compu-
tation of Z’s modified basis remains at $55X. Next,
these amounts must be reduced by any distributions
between the beginning of the day on January 1, 2024,
and noon on August 29, 2024. Because there were
none, after this step, the computation of P’s modi-
fied basis remains at $20X, the computation of Q’s
modified basis remains at $30X, and the computation
of Z’s modified basis remains at $55X. Finally, the
full amount of P’s, Q’s, and Z’s shares of §1.752-1
liabilities must be subtracted. Because there were
none, P’s modified basis is $20X, Q’s modified basis
is $30X, and Z’s modified basis is $55X.
(m) Allocation of modified basis—(1) In general.
An allocation of an ultimate member’s modified
basis to the portion of the real property with respect
to which the qualified conservation contribution is
made must be made in accordance with this para-
graph (m). Rules for allocating an ultimate mem-
ber’s modified basis in a contributing partnership are
provided in paragraph (m)(2) of this section. Rules
for allocating an ultimate member’s modified basis
in a contributing S corporation are provided in para-
graph (m)(3) of this section. Rules for allocating an
ultimate member’s modified basis in an upper-tier
partnership are provided in paragraph (m)(4) of this
section. Rules for allocating an ultimate member’s
modified basis in an upper-tier S corporation are pro-
vided in paragraph (m)(5) of this section. Records
must be kept in accordance with paragraph (m)(6)
of this section.
(2) Determination of relevant basis
for an ultimate member holding a direct

July 22, 2024 110 Bulletin No. 2024–30
interest in a contributing partnership—
(i) Narrative rule. This paragraph (m)(2)
applies in the case of an ultimate member
holding a direct interest in a contributing
partnership and provides that a contrib-
uting partnership must determine each
such ultimate member’s relevant basis as
provided in this paragraph (m)(2). Rele-
vant basis equals each ultimate member’s
modified basis as determined under para-
graph (l)(2) of this section multiplied by
a fraction–
(A) The numerator of which is the ulti-
mate member’s share of the contributing
partnership’s adjusted basis in the portion
of the real property with respect to which
the qualified conservation contribution is
made as determined under paragraph (m)
(2)(ii) of this section; and
(B) The denominator of which is the
ultimate member’s portion of the adjusted
basis in all the contributing partnership’s
properties as determined under paragraph
(m)(2)(iii) of this section.
(ii) Ultimate member’s share of the
contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conserva-
tion contribution is made. For purposes
of this paragraph (m)(2), an ultimate
member’s share of the contributing part-
nership’s adjusted basis in the portion of
the real property with respect to which
the qualified conservation contribution is
made equals the contributing partnership’s
adjusted basis in the portion of the real
property with respect to which the qual-
ified conservation contribution is made
(determined as of the time of day of the
contribution) multiplied by a fraction–
(A) The numerator of which is the ulti-
mate member’s distributive share of the
qualified conservation contribution; and
(B) The denominator of which is the
total amount of the contributing partner-
ship’s qualified conservation contribution.
(iii) Ultimate member’s portion of the
adjusted basis in all the contributing part-
nership’s properties—(A) For purposes of
this paragraph (m)(2), an ultimate mem-
ber’s portion of the adjusted basis in all
the contributing partnership’s properties is
equal to the sum of:
(1) The ultimate member’s share of the
contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conserva-
tion contribution is made as determined
under paragraph (m)(2)(ii) of this section;
plus
(2) The ultimate member’s portion of
the adjusted basis in all the contributing
partnership’s properties other than the
portion of the real property with respect
to which the qualified conservation contri-
bution is made as determined under para-
graph (m)(2)(iii)(B) of this section.
(B) To determine a partner’s portion
of the adjusted basis in all of a contribut-
ing partnership’s properties, the contrib-
uting partnership must apportion among
its partners its adjusted basis in each of
its properties (except the portion of the
real property with respect to which the
qualified conservation contribution is
made), using the adjusted basis imme-
diately before the qualified conserva-
tion contribution, without duplication or
omission of any property, and by treating
the adjusted basis in each property as not
less than zero. This apportionment must
be done under principles similar to the
determination of the partners’ interests
in the partnership under section 704(b),
including the factors in §1.704-1(b)(3)
(ii). In addition, the apportionment must
reflect section 704(c) principles. For
example, if a partnership property has
built-in loss (the adjusted basis of the
property exceeds its fair market value),
and section 704(c) would require all of
that built-in loss to be allocated to a cer-
tain partner if that property was sold, all
of the basis in the property that exceeds
the property’s fair market value must be
apportioned to the partner to whom the
loss would be allocated if the property
was sold.
(iv) Formulaic rule. The rule of this
paragraph (m)(2) is also expressed in the
following formula:
Equation 1 to Paragraph (m)(2)(iv)
R = M × (T ÷ (D + T))
Where:
R = Relevant basis.
M = Modified basis as determined
under paragraph (l) of this section.
D = Ultimate member’s portion of
the adjusted basis in all the con-
tributing partnership’s properties
(other than the portion of the real
property with respect to which the
qualified conservation contribu-
tion is made) as determined under
paragraph (m)(2)(iii)(B) of this
section.
T = Ultimate member’s share of
the contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made, determined
according to the following for-
mula: A × (B ÷ C).
A = Contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made.
B = Ultimate member’s distributive
share of the qualified conservation
contribution.
C = Total amount of the contributing
partnership’s qualified conserva-
tion contribution.
(3) Determination of relevant basis
for an ultimate member holding a direct
interest in a contributing S corporation—
(i) Narrative rule. This paragraph (m)(3)
applies in the case of an ultimate member
holding a direct interest in a contributing
S corporation and provides that a contrib-
uting S corporation must determine each
such ultimate member’s relevant basis as
provided in this paragraph (m)(3). Rele-
vant basis equals each ultimate member’s
modified basis as determined under para-
graph (l)(3) of this section multiplied by
a fraction–
(A) The numerator of which is the
ultimate member’s pro rata portion of
the contributing S corporation’s adjusted
basis in the portion of the real property
with respect to which the qualified conser-
vation contribution is made; and
(B) The denominator of which is the
ultimate member’s pro rata portion of
the adjusted basis in all the contributing
S corporation’s properties (including the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made).
(ii) Formulaic rule. The rule of this
paragraph (m)(3) is also expressed in the
following formula:
Equation 2 to Paragraph (m)(3)(ii)
R = M × (E ÷ F)

Bulletin No. 2024–30 111 July 22, 2024
Where:
R = Relevant basis.
M = Modified basis as determined
under paragraph (l) of this section.
E = Ultimate member’s pro rata por-
tion of the contributing S corpora-
tion’s adjusted basis in the portion
of the real property with respect to
which the qualified conservation
contribution is made.
F = Ultimate member’s pro rata por-
tion of the adjusted basis in all
the contributing S corporation’s
properties (including the portion
of the real property with respect
to which the qualified conserva-
tion contribution is made).
(4) Determination of relevant basis
for an ultimate member holding a direct
interest in an upper-tier partnership—(i)
In general. This paragraph (m)(4) applies
in the case of an ultimate member hold-
ing a direct interest in an upper-tier part-
nership. Each such ultimate member’s
modified basis must be traced through
all upper-tier partnerships to the con-
tributing partnership, and the contribut-
ing partnership must determine the rel-
evant basis. This involves a multi-step
process under which, beginning with
the upper-tier partnership in which the
ultimate member holds a direct interest,
each upper-tier partnership must per-
form calculations, and then finally the
contributing partnership must use those
calculations to compute the ultimate
member’s relevant basis. For simplicity,
this paragraph (m)(4) describes a situa-
tion in which there are two tiers of part-
nerships—a contributing partnership and
an upper-tier partnership. In a situation
involving more tiers, each partnership
must apply the rules and principles of
this paragraph (m)(4) iteratively to deter-
mine relevant basis.
(ii) Upper-tier partnership—(A)
Narrative rule—(1) In general. The
upper-tier partnership must determine
the portion of each ultimate member’s
modified basis that is allocable to the
upper-tier partnership’s interest in the
partnership in which it holds a direct
interest (in a situation involving only
two tiers of partnerships, that will be the
contributing partnership). This determi-
nation must be done in accordance with
the principles of paragraph (m)(2) of
this section, the rule in paragraph (m)
(4)(ii)(A)(2) of this section, and the for-
mula provided in paragraph (m)(4)(ii)
(B) of this section. In other words, the
formula provided in paragraph (m)(4)
(ii)(B) of this section is similar to the
formula provided in paragraph (m)(2)
(iv) of this section, except that, instead
of determining the portion of modified
basis that is allocable to the portion of
the real property with respect to which
the qualified conservation contribution
is made, the formula in paragraph (m)
(4)(ii)(B) of this section determines the
portion of modified basis that is alloca-
ble to the upper-tier partnership’s inter-
est in the next lower-tier partnership.
As explained in paragraph (m)(4)(iii)
of this section, the contributing part-
nership will then use the amount deter-
mined under the formula in paragraph
(m)(4)(ii)(B) of this section to compute
the portion of modified basis that is
allocable to the portion of the real prop-
erty with respect to which the qualified
conservation contribution is made.
(2) Apportionment of upper-tier part-
nership’s adjusted bases in its properties.
To determine a partner’s portion of the
adjusted basis in all of an upper-tier part-
nership’s properties, the upper-tier part-
nership must apportion among its partners
its adjusted basis in each of its properties
(except its interest in the lower-tier part-
nership), using the adjusted basis imme-
diately before the qualified conservation
contribution, without duplication or
omission of any property, and by treating
the adjusted basis in each property as not
less than zero. This apportionment must
be done under principles similar to the
determination of the partners’ interests
in the partnership under section 704(b),
including the factors in §1.704-1(b)(3)
(ii). In addition, the apportionment must
reflect section 704(c) principles. For
example, if a partnership property has
built-in loss (the adjusted basis of the
property exceeds its fair market value),
and section 704(c) would require all of
that built-in loss to be allocated to a cer-
tain partner if that property was sold, all
of the basis in the property that exceeds
the property’s fair market value must be
apportioned to the partner to whom the
loss would be allocated if the property
was sold.
(B) Formulaic rule. The rule of this
paragraph (m)(4)(ii) is also expressed in
the following formula:
Equation 3 to Paragraph (m)(4)(ii)(B)
G = M × (U ÷ (J + U))
Where:
G = The portion of the ultimate mem-
ber’s modified basis that is alloca-
ble to the upper-tier partnership’s
interest in the contributing part-
nership.
M = Modified basis as determined
under paragraph (l) of this section.
J = Ultimate member’s portion of the
adjusted basis in all the upper-tier
partnership’s properties (other
than the upper-tier partnership’s
interest in the contributing part-
nership) as determined under
paragraph (m)(4)(ii)(A)(2) of this
section.
U = Ultimate member’s share of the
upper-tier partnership’s adjusted
basis in its interest in the con-
tributing partnership, determined
according to the following for-
mula: H × (B ÷ K).
H = Upper-tier partnership’s adjusted
basis in its interest in the contrib-
uting partnership.
B = Ultimate member’s distributive
share of the qualified conservation
contribution.
K = Upper-tier partnership’s allocated
portion of the qualified conserva-
tion contribution.
(iii) Contributing partnership—(A)
Narrative rule. After completion of the
computations under paragraph (m)(4)(ii)
of this section, the contributing partner-
ship must determine the portion of the
amount determined under item G (see
paragraph (m)(4)(ii)(B) of this section)
with respect to each ultimate member
that is allocable to the portion of the
real property with respect to which the
qualified conservation contribution is
made. This determination must be done
in accordance with the principles of para-
graph (m)(2) of this section and the for-
mula provided in paragraph (m)(4)(iii)
(B) of this section.
(B) Formulaic rule. The rule of this
paragraph (m)(4)(iii) is also expressed in
the following formula:

July 22, 2024 112 Bulletin No. 2024–30
Equation 4 to Paragraph (m)(4)(iii)(B)
R = G × (V ÷ (L + V))
Where:
R = Relevant basis.
G = Amount determined with respect
to item G as described under para-
graph (m)(4)(ii)(B) of this section.
L = Upper-tier partnership’s portion
of adjusted basis in all the con-
tributing partnership’s properties
(other than the portion of the real
property with respect to which the
qualified conservation contribu-
tion is made) as determined under
paragraph (m)(2)(iii)(B) of this
section.
V = Upper-tier partnership’s share
of the contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made, determined
according to the following for-
mula: A × (K ÷ C).
A = Contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made.
K = Upper-tier partnership’s allocated
portion of the qualified conserva-
tion contribution.
C = Total amount of the contributing
partnership’s qualified conserva-
tion contribution.
(5) Determination of relevant basis
for an ultimate member holding a direct
interest in an upper-tier S corporation—
(i) In general. This paragraph (m)(5)
applies in the case of an ultimate mem-
ber holding a direct interest in an upper-
tier S corporation. Each such ultimate
member’s modified basis must be traced
through the upper-tier S corporation and
any upper-tier partnerships to the contrib-
uting partnership, and the contributing
partnership must determine the relevant
basis. This involves a multi-step process
under which, beginning with the upper-
tier S corporation, the upper-tier S cor-
poration and any upper-tier partnerships
must perform calculations, and then
finally the contributing partnership must
use those calculations to compute the ulti-
mate member’s relevant basis. For sim-
plicity, this paragraph (m)(5) describes a
situation in which there are two tiers—a
contributing partnership and an upper-
tier S corporation. In a situation involv-
ing more tiers, each partnership and the
upper-tier S corporation must apply the
rules and principles of this paragraph (m)
iteratively to determine relevant basis.
(ii) Upper-tier S corporation—(A)
Narrative rule. The upper-tier S corpora-
tion must determine the portion of each
ultimate member’s modified basis that is
allocable to the upper-tier S corporation’s
interest in the partnership in which it holds
a direct interest (in a situation involving
only two tiers, that will be the contribut-
ing partnership). This determination must
be done in accordance with the principles
of paragraph (m)(3) of this section and
the formula provided in paragraph (m)
(5)(ii)(B) of this section. In other words,
the formula provided in paragraph (m)
(5)(ii)(B) of this section is similar to the
formula provided in paragraph (m)(3)
(ii) of this section, except that, instead
of determining the portion of modified
basis that is allocable to the portion of
the real property with respect to which
the qualified conservation contribution is
made, the formula in paragraph (m)(5)(ii)
(B) of this section determines the portion
of modified basis that is allocable to the
upper-tier S corporation’s interest in the
next lower-tier partnership. As explained
in paragraph (m)(5)(iii) of this section, the
contributing partnership will then use the
amount determined under the formula in
paragraph (m)(5)(ii)(B) of this section to
compute the portion of modified basis that
is allocable to the portion of the real prop-
erty with respect to which the qualified
conservation contribution is made.
(B) Formulaic rule. The rule of this
paragraph (m)(5)(ii) is also expressed in
the following formula:
Equation 5 to Paragraph (m)(5)(ii)(B)
N = M × (P ÷ Q)
Where:
N = Portion of the ultimate member’s
modified basis that is allocable
to the upper-tier S corporation’s
interest in the contributing part-
nership.
M = Modified basis as determined
under paragraph (l) of this section.
P = Ultimate member’s pro rata por-
tion of the upper-tier S corpora-
tion’s adjusted basis in its interest
in the contributing partnership.
Q = Ultimate member’s pro rata por-
tion of the adjusted basis in all the
upper-tier S corporation’s prop-
erties (including the upper-tier S
corporation’s interest in the con-
tributing partnership).
(iii) Contributing partnership—(A)
Narrative rule. After completion of the
computations under paragraph (m)(5)(ii)
of this section, the contributing partner-
ship must determine the portion of the
amount determined under item N (see
paragraph (m)(5)(ii)(B) of this section)
with respect to each ultimate member that
is allocable to the portion of the real prop-
erty with respect to which the qualified
conservation contribution is made. This
determination must be done in accordance
with the principles of paragraph (m)(2) of
this section and the formula provided in
paragraph (m)(5)(iii)(B) of this section.
(B) Formulaic rule. The rule of this
paragraph (m)(5)(iii) is also expressed in
the following formula:
Equation 6 to Paragraph (m)(5)(iii)(B)
R = N × (W ÷ (S + W))
Where:
R = Relevant basis.
N = Amount determined with respect
to item N as described under para-
graph (m)(5)(ii)(B) of this section.
S = Upper-tier S corporation’s portion
of the adjusted basis in all the con-
tributing partnership’s properties
(other than the portion of the real
property with respect to which the
qualified conservation contribu-
tion is made) as determined under
paragraph (m)(2)(iii)(B) of this
section.
W = Upper-tier S corporation’s share
of the contributing partnership’s
adjusted basis in the portion of
the real property with respect to
which the qualified conservation
contribution is made, determined
according to the following for-
mula: A × (Y ÷ C).
A = Contributing partnership’s
adjusted basis in the portion of
the real property with respect to

Bulletin No. 2024–30 113 July 22, 2024
which the qualified conservation
contribution is made.
Y = Upper-tier S corporation’s allo-
cated portion of the qualified con-
servation contribution.
C = Total amount of the contributing
partnership’s qualified conserva-
tion contribution.
(6) Recordkeeping requirements. Con-
tributing partnerships, contributing S cor-
porations, upper-tier partnerships, and
upper-tier S corporations must maintain
dated, written statements in their books
and records, by the due date, including
extensions, of their Federal income tax
returns, substantiating the computation
of each ultimate member’s adjusted
basis, modified basis, and relevant basis.
See §1.6001-1. These statements need
not be maintained (nor does modified
basis or relevant basis need to be com-
puted) with respect to contributions that
meet an exception in paragraph (n)(2) or
(3) of this section, unless the contribution
also meets the exception in paragraph (n)
(4) of this section (in which case these
statements need to be maintained and
modified basis and relevant basis need to
be computed).
(7) Examples. The following examples
illustrate the provisions of this paragraph
(m). For the examples in this paragraph
(m)(7), assume that the partnership alloca-
tions comply with the rules of subchapter
K of chapter 1 of the Code and the excep-
tions in paragraph (n) of this section do
not apply.
(i) Example 1—(A) Facts. YZ Partnership is a
partnership for Federal income tax purposes whose
partners are individuals Y and Z. YZ Partnership
owns 100 acres of real property with an adjusted
basis of $10X. YZ Partnership makes a qualified
conservation contribution on 60 acres of the prop-
erty. YZ Partnership claims a contribution of $18X,
which it allocates $12X to Y and $6X to Z. YZ Part-
nership’s adjusted basis in the 60 acres is $6X, and
its adjusted basis in all of its other properties (includ-
ing its $4X basis in the 40 acres on which a qualified
conservation contribution was not made) is $18X.
Y’s modified basis is $8X. Y’s portion of YZ Part-
nership’s adjusted basis in all partnership property
(other than the 60 acres) as determined under para-
graph (m)(2)(iii)(B) of this section is $4X. Z’s mod-
ified basis is $12X. Z’s portion of YZ Partnership’s
adjusted basis in all partnership property (other than
the 60 acres) as determined under paragraph (m)(2)
(iii)(B) of this section is $14X.
(B) General analysis. Y and Z are the ultimate
members of YZ Partnership because they each
receive a distributive share of the qualified conser-
vation contribution and are not partnerships or S cor-
porations. Their relevant bases must be determined
according to the following formula:
Equation 7 to Paragraph (m)(7)(i)(B)
R = M × (T ÷ (D + T))
Where:
R = Relevant basis.
M = Modified basis as determined under para-
graph (l) of this section.
D = Ultimate member’s portion of the adjusted
basis in all of the contributing partner-
ship’s properties (other than the portion
of the real property with respect to which
the qualified conservation contribution is
made) as determined under paragraph (m)
(2)(iii)(B) of this section.
T = Ultimate member’s share of the contrib-
uting partnership’s adjusted basis in the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made, determined according to the
following formula: A × (B ÷ C).
A = Contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conservation
contribution is made.
B = Ultimate member’s distributive share of
the qualified conservation contribution.
C = Total amount of the contributing partner-
ship’s qualified conservation contribution.
(C) Y’s relevant basis. With respect to Y:
(1) M = $8X.
(2) D = $4X.
(3) A = $6X.
(4) B = $12X.
(5) C = $18X.
(6) Thus, T is $4X = $6X × ($12X ÷ $18X).
(7) Accordingly, Y’s relevant basis is $4X = $8X
× ($4X ÷ ($4X + $4X)).
(D) Z’s relevant basis. With respect to Z:
(1) M = $12X.
(2) D = $14X.
(3) A = $6X.
(4) B = $6X.
(5) C = $18X.
(6) Thus, T is $2X = $6X × ($6X ÷ $18X).
(7) Accordingly, Z’s relevant basis is $1.5X =
$12X × ($2X ÷ ($14X + $2X)).
(E) Sum of the relevant bases. The amount of YZ
Partnership’s claimed contribution is $18X, which
exceeds 2.5 times the sum of Y’s and Z’s relevant
bases, which is $13.75X ($13.75X = 2.5 x (Y’s rel-
evant basis of $4X + Z’s relevant basis of $1.5X)).
Accordingly, YZ Partnership’s contribution is a
disallowed qualified conservation contribution. No
person may claim any deduction with respect to this
contribution.
(ii) Example 2—(A) Facts. CD Inc. is an S cor-
poration with shareholders C and D, each of whom is
an individual that is not a nonresident alien. C owns
one third of the outstanding stock in CD Inc., and D
owns the remaining two thirds. CD Inc. owns 100
acres of real property with an adjusted basis of $10X.
CD Inc. makes a qualified conservation contribution
on 60 acres of the property. CD Inc. claims a contri-
bution of $9X, which it allocates $3X to C and $6X
to D. CD Inc.’s adjusted basis in the 60 acres is $6X,
and its adjusted basis in all its properties (including
its $6X basis in the 60 acres) is $24X. C’s modified
basis in CD Inc. is $8X. D’s modified basis in CD
Inc. is $12X.
(B) General analysis. C and D are the ultimate
members of CD Inc. because they each receive a pro
rata share of the qualified conservation contribution
and are not partnerships or S corporations. Their
relevant bases must be determined according to the
following formula:
Equation 8 to Paragraph (m)(7)(ii)(B)
R = M × (E ÷ F)
Where:
R = Relevant basis.
M = Modified basis as determined under para-
graph (l) of this section.
E = Ultimate member’s pro rata portion of the
contributing S corporation’s adjusted basis
in the portion of the real property with
respect to which the qualified conservation
contribution is made.
F = Ultimate member’s pro rata portion of
the adjusted basis in all the contributing
S corporation’s properties (including the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made).
(C) C’s relevant basis. With respect to C:
(1) M = $8X.
(2) E = $2X (1/3 of $6X).
(3) F = $8X (1/3 of $24X).
(4) Thus, C’s relevant basis is $2X = $8X × ($2X
÷ $8X).
(D) D’s relevant basis. With respect to D:
(1) M = $12X.
(2) E = $4X (2/3 of $6X).
(3) F = $16X (2/3 of $24X).
(4) Thus, D’s relevant basis is $3X = $12X ×
($4X ÷ $16X).
(E) Sum of the relevant bases. The amount of CD
Inc.’s claimed qualified conservation contribution is
$9X, which does not exceed 2.5 times the sum of C’s
and D’s relevant bases, which is $12.50X ($12.50X
= 2.5 x (C’s relevant basis of $2X + D’s relevant
basis of $3X)). Accordingly, CD Inc.’s contribution
is not a disallowed qualified conservation contribu-
tion (that is, is not disallowed by section 170(h)(7)
and paragraph (j) of this section).
(iii) Example 3—(A) Facts. LTP Partnership is a
partnership for Federal income tax purposes whose
partners are individual E and UTP Partnership, a
partnership for Federal income tax purposes. UTP
Partnership’s partners are C corporations P and Q.
LTP Partnership owns 300 acres of real property.
LTP Partnership makes a qualified conservation con-
tribution on all 300 acres. LTP Partnership claims a
qualified conservation contribution of $22X, which
it allocates $2X to E and $20X to UTP Partnership.
UTP Partnership allocates its $20X share of the qual-
ified conservation contribution $6X to P and $14X to
Q. LTP Partnership’s basis in the 300 acres is $18X,
and its adjusted basis in all of its other properties is
$12X. E’s modified basis in LTP Partnership is $4X.
E’s portion of LTP Partnership’s adjusted basis in
all partnership property (other than the 300 acres)
as determined under paragraph (m)(2)(iii)(B) of this

July 22, 2024 114 Bulletin No. 2024–30
section is $4.36X. UTP Partnership’s portion of LTP
Partnership’s adjusted basis in all partnership prop-
erty (other than the 300 acres) as determined under
paragraph (m)(2)(iii)(B) of this section is $7.64X.
UTP Partnership’s adjusted basis in its interest in
LTP Partnership is $19X, and its adjusted basis in all
other properties is $6X. P’s modified basis in UTP
Partnership is $12X. P’s portion of UTP Partnership’s
adjusted basis in all partnership property (other than
the interest in LTP Partnership) as determined under
paragraph (m)(4)(ii)(A)(2) of this section is $3.6X.
Q’s modified basis in UTP Partnership is $8X. Q’s
portion of UTP Partnership’s adjusted basis of all
partnership property (other than the interest in LTP
Partnership) as determined under paragraph (m)(4)
(ii)(A)(2) of this section is $2.4X.
(B) Analysis: partner E. (1) The ultimate mem-
bers of LTP Partnership are E, P, and Q because they
each receive a distributive share of the qualified
conservation contribution and are not partnerships
or S corporations. Because E holds a direct interest
in LTP Partnership, E’s relevant basis must be deter-
mined in accordance with the following formula:
Equation 9 to Paragraph (m)(7)(iii)(B)(1)
R = M × (T ÷ (D + T))
Where:
R = Relevant basis.
M = Modified basis as determined under para-
graph (l) of this section.
D = Ultimate member’s portion of the adjusted
basis in all the contributing partnership’s
properties (other than the portion of the
real property with respect to which the
qualified conservation contribution is
made) as determined under paragraph (m)
(2)(iii)(B) of this section.
T = Ultimate member’s share of the contrib-
uting partnership’s adjusted basis in the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made, determined according to the
following formula: A × (B ÷ C).
A = Contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conservation
contribution is made.
B = Ultimate member’s distributive share of
the qualified conservation contribution.
C = Total amount of the contributing partner-
ship’s qualified conservation contribution.
(2) With respect to E:
(i) M = $4X.
(ii) D = $4.36X.
(iii) A = $18X.
(iv) B = $2X.
(v) C = $22X.
(vi) Thus, T is $1.64X = $18X × ($2X ÷ $22X).
(vii) Accordingly, E’s relevant basis is $1.09X =
$4X × ($1.64X ÷ ($4.36X + $1.64X)).
(C) Analysis: General rule for UTP Partner-
ship. Because P and Q hold interests in an upper-tier
partnership, UTP Partnership must first determine
the portions of P’s and Q’s modified bases that are
allocable to UTP Partnership’s interest in LTP Part-
nership. This is to be done according to the following
formula:
Equation 10 to Paragraph (m)(7)(iii)(C)
G = M × (U ÷ (J + U))
Where:
G = The portion of the ultimate member’s mod-
ified basis that is allocable to the upper-tier
partnership’s interest in the contributing
partnership.
M = Modified basis as determined under para-
graph (l) of this section.
J = Ultimate member’s portion of adjusted
basis in all the upper-tier partnership’s
properties (other than the upper-tier part-
nership’s interest in the contributing part-
nership) as determined under paragraph
(m)(4)(ii)(A)(2) of this section.
U = Ultimate member’s share of the upper-tier
partnership’s adjusted basis in its interest
in the contributing partnership, determined
according to the following formula: H × (B
÷ K).
H = Upper-tier partnership’s adjusted basis in
its interest in the contributing partnership.
B = Ultimate member’s distributive share of
the qualified conservation contribution.
K = Upper-tier partnership’s allocated portion
of the qualified conservation contribution.
(D) Analysis: Step 1 for P. With respect to P:
(1) M = $12X.
(2) J = $3.6X.
(3) H = $19X.
(4) B = $6X.
(5) K = $20X.
(6) Thus, U is $5.70X = $19X × ($6X ÷ $20X).
(7) Accordingly, the portion of P’s modified basis
that is allocable to UTP Partnership’s interest in LTP
Partnership is $7.35X = $12X × ($5.70X ÷ ($3.60X
+ $5.70X)).
(E) Analysis: Step 1 for Q. With respect to Q:
(1) M = $8X.
(2) J = $2.4X.
(3) H = $19X.
(4) B = $14X.
(5) K = $20X.
(6) Thus, U is $13.30X = $19X × ($14X ÷ $20X).
(7) Accordingly, the portion of Q’s modified
basis that is allocable to UTP Partnership’s interest
in LTP Partnership is $6.78X = $8X × ($13.30X ÷
($2.40X + $13.30X)).
(F) Analysis: General rule for LTP Partner-
ship. Next, LTP Partnership must determine P’s and
Q’s relevant bases, which equal the portions of the
amounts determined under paragraphs (m)(7)(iii)(D)
and (E) of this section (Example 3) that are alloca-
ble to the portion of the real property with respect
to which the qualified conservation contribution was
made. This must be done according to the following
formula:
Equation 11 to Paragraph (m)(7)(iii)(F)
R = G × (V ÷ (L + V))
Where:
R = Relevant basis.
G = Amount determined with respect to item G
under paragraph (m)(4)(ii)(B) of this sec-
tion.
L = Upper-tier partnership’s portion of
adjusted basis in all the contributing part-
nership’s properties (other than the portion
of the real property with respect to which
the qualified conservation contribution is
made) as determined under paragraph (m)
(2)(iii)(B) of this section.
V = Upper-tier partnership’s share of the con-
tributing partnership’s adjusted basis in the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made, determined according to the
following formula: A × (K ÷ C).
A = Contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conservation
contribution is made.
K = Upper-tier partnership’s allocated portion
of the qualified conservation contribution.
C = Total amount of the contributing partner-
ship’s qualified conservation contribution.
(G) Analysis: Step 2 for P. With respect to P:
(1) G = $7.35X.
(2) L = $7.64X.
(3) A = $18X.
(4) K = $20X.
(5) C = $22X.
(6) Thus, V is $16.36X = $18X × ($20X ÷ $22X).
(7) Accordingly, P’s relevant basis is $5.01X =
$7.35X × ($16.36X ÷ ($7.64X + $16.36X)).
(H) Analysis: Step 2 for Q. With respect to Q:
(1) G = $6.78X.
(2) L = $7.64X.
(3) A = $18X.
(4) K = $20X.
(5) C = $22X.
(6) Thus, V is $16.36X = $18X × ($20X ÷ $22X).
(7) Accordingly, Q’s relevant basis is $4.62X =
$6.78X × ($16.36X ÷ ($7.64X + $16.36X)).
(I) Analysis: Computation of 2.5 times sum of the
relevant bases. The ultimate members of LTP Partner-
ship are E, P, and Q. The amount of LTP Partnership’s
qualified conservation contribution is $22X. This
does not exceed 2.5 times the sum of each of the ulti-
mate member’s relevant basis, which totals $26.80X
($26.80X = 2.5 x (E’s relevant basis of 1.09X +
P’s relevant basis of $5.01X + Q’s relevant basis of
$4.62X)). Therefore, LTP Partnership’s contribution
is not a disallowed qualified conservation contribu-
tion (that is, is not disallowed by section 170(h)(7)
and paragraph (j) of this section). Because UTP Part-
nership receives an allocated portion, it must apply
paragraphs (j) through (l) of this section and this para-
graph (m) to determine whether its allocated portion is
a disallowed qualified conservation contribution. The
ultimate members of UTP Partnership are P and Q.
The amount of UTP Partnership’s allocated portion of
LTP Partnership’s qualified conservation contribution
is $20X. This does not exceed 2.5 times the sum of P’s
and Q’s relevant bases, which is $24.08X ($24.08X =
2.5 x (P’s relevant basis of $5.01X + Q’s relevant basis
of $4.62X)). Therefore, UTP Partnership’s allocated
portion of LTP Partnership’s contribution is not a dis-
allowed qualified conservation contribution (that is, is
not disallowed by section 170(h)(7) and paragraph (j)
of this section).
(iv) Example 4—(A) Facts. Individuals V and
W form VW Partnership, a partnership for Fed-

Bulletin No. 2024–30 115 July 22, 2024
eral income tax purposes. V and W each hold a
fifty percent interest in all of VW Partnership’s
items of income, gain, loss, deduction, credits,
and charitable contributions. On formation of VW
Partnership, V contributes $1,000X cash to VW
Partnership and W contributes GainProp, which is
non-depreciable property with a value of $1,000X
and basis of $500X. VW Partnership buys real
property (RealProp), with its $1,000X cash. Later,
at a time when VW Partnership’s basis in Real-
Prop is still $1,000X, and its basis in GainProp
is still $500X, VW Partnership makes a qualified
conservation contribution with respect to all of
RealProp, which it allocates equally to V and W.
VW Partnership continues to hold GainProp. V’s
modified basis is $1,000X and W’s modified basis
is $500X.
(B) General analysis. V and W are the ultimate
members of VW Partnership because they each
receive a distributive share of the qualified conser-
vation contribution and are not partnerships or S cor-
porations. Their relevant bases must be determined
according to the following formula:
Equation 12 to Paragraph (m)(7)(iv)(B)
R = M × (T ÷ (D + T))
Where:
R = Relevant basis.
M = Modified basis as determined under para-
graph (l) of this section.
D = Ultimate member’s portion of the adjusted
basis in all of the contributing partner-
ship’s properties (other than the portion
of the real property with respect to which
the qualified conservation contribution is
made) as determined under paragraph (m)
(2)(iii)(B) of this section.
T = Ultimate member’s share of the contrib-
uting partnership’s adjusted basis in the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made, determined according to the
following formula: A × (B ÷ C).
A = Contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conservation
contribution is made.
B = Ultimate member’s distributive share of
the qualified conservation contribution.
C = Total amount of the contributing partner-
ship’s qualified conservation contribution.
(C) V’s relevant basis. With respect to V:
(1) M = $1,000X.
(2) D = $250X (half of VW Partnership’s
adjusted basis in GainProp).
(3) T = $500X (half of VW Partnership’s adjusted
basis in RealProp).
(4) Accordingly, V’s relevant basis is $666.67X
= $1,000X × ($500X ÷ ($250X + $500X)).
(D) W’s relevant basis. With respect to W:
(1) M = $500X.
(2) D = $250X (half of VW Partnership’s basis
in GainProp).
(3) T = $500X (half of VW Partnership’s adjusted
basis in RealProp).
(4) Accordingly, W’s relevant basis is $333.33X
= $500X × ($500X ÷ ($250X + $500X)).
(v) Example 5—(A) Facts. Assume the same
facts as in paragraph (m)(7)(iv) of this section (Exam-
ple 4), except that W does not contribute GainProp;
instead, W contributes LossProp, which is non-de-
preciable property with a value of $1,000X and basis
of $2,000X. At the time that VW Partnership makes
the qualified conservation contribution on RealProp,
the value of LossProp is still $1,000X and the basis
of LossProp is still $2,000X. V’s modified basis is
$1,000X and W’s modified basis is $2,000X.
(B) General analysis. V and W are the ultimate
members of VW Partnership because they each
receive a distributive share of the qualified conser-
vation contribution and are not partnerships or S cor-
porations. Their relevant bases must be determined
according to the following formula:
Equation 13 to Paragraph (m)(7)(v)(B)
R = M × (T ÷ (D + T))
Where:
R = Relevant basis.
M = Modified basis as determined under para-
graph (l) of this section.
D = Ultimate member’s portion of the adjusted
basis in all of the contributing partner-
ship’s properties (other than the portion
of the real property with respect to which
the qualified conservation contribution is
made) as determined under paragraph (m)
(2)(iii)(B) of this section.
T = Ultimate member’s share of the contrib-
uting partnership’s adjusted basis in the
portion of the real property with respect to
which the qualified conservation contribu-
tion is made, determined according to the
following formula: A × (B ÷ C).
A = Contributing partnership’s adjusted basis
in the portion of the real property with
respect to which the qualified conservation
contribution is made.
B = Ultimate member’s distributive share of
the qualified conservation contribution.
C = Total amount of the contributing partner-
ship’s qualified conservation contribution.
(C) V’s relevant basis. With respect to V:
(1) M = $1,000X.
(2) D = $500X (half of the $1,000X portion
of LossProp’s adjusted basis that does not exceed
LossProp’s $1,000X value)
(3) T = $500X (half of VW Partnership’s adjusted
basis in RealProp)
(4) Accordingly, V’s relevant basis is $500X =
$1,000X × ($500X ÷ ($500X + $500X)).
(D) W’s relevant basis. With respect to W:
(1) M = $2,000X.
(2) D = $1,500X (half of the $1,000X portion
LossProp’s adjusted basis that does not exceed
LossProp’s $1,000X value, plus all of the $1,000X
portion of LossProp’s adjusted basis in excess of
LossProp’s $1,000X value).
(3) T = $500X (half of VW Partnership’s adjusted
basis in RealProp).
(4) Accordingly, W’s relevant basis is $500X =
$2,000X × ($500X ÷ ($1,500X + $500X)).
(n) Exceptions—(1) In general. Para-
graph (j) of this section does not apply
to any qualified conservation contribu-
tion that satisfies one or more of the three
exceptions in this paragraph (n). How-
ever, as provided in paragraph (j)(5) of
this section, there is no presumption that
a contribution that satisfies one or more
of the three exceptions in this paragraph
(n) is compliant with section 170, any
other section of the Code, the regulations
in this part, or any other guidance. Being
described in this paragraph (n) is not a safe
harbor for purposes of any other provision
of law or with respect to the value of the
contribution. Such transactions are sub-
ject to adjustment or disallowance for any
other reason, including failure to satisfy
other requirements of section 170 or over-
valuation of the contribution. In addition,
taxpayers who engage in transactions that
satisfy one or more of the three exceptions
in this paragraph (n) may nonetheless be
required to disclose, under §1.6011-4, the
transactions as listed transactions.
(2) Exception for contributions outside
three-year holding period—(i) In general.
Paragraph (j) of this section does not apply
to any qualified conservation contribution
by a contributing partnership or contribut-
ing S corporation made at least three years
after the latest of—
(A) The last date on which the contrib-
uting partnership or contributing S cor-
poration acquired any portion of the real
property with respect to which such quali-
fied conservation contribution is made;
(B) The last date on which any partner
in the contributing partnership or share-
holder in the contributing S corporation
acquired any interest in such partnership
or S corporation; and
(C) If the interest in the contributing
partnership is held through one or more
upper-tier partnerships or upper-tier S cor-
porations—
(1) The last date on which any such
upper-tier partnership or upper-tier S cor-
poration acquired any interest in the con-
tributing partnership or any other upper-
tier partnership; and
(2) The last date on which any part-
ner or shareholder in any such upper-tier
partnership or upper-tier S corporation
acquired any interest in such upper-tier
partnership or upper-tier S corporation.
(ii) Acquisition of partnership interest.
For purposes of this paragraph (n)(2), an
acquisition of any interest in a partner-
ship is any variation within the meaning

July 22, 2024 116 Bulletin No. 2024–30
of that term in §1.706-4(a)(1); however,
a variation does not include a change in
allocations that satisfies the requirements
of §1.706-4(b)(1).
(iii) Acquisition of interest in an S cor-
poration. For purposes of this paragraph
(n)(2), an acquisition of any interest in an
S corporation is any transfer, issuance,
redemption, or other disposition of stock
in the S corporation; however, an acqui-
sition does not include any issuance or
redemption involving all shareholders that
does not affect the proportionate owner-
ship of any shareholder.
(iv) Exception is determined at the level
of the contributing partnership or contrib-
uting S corporation. If the contributing
partnership or contributing S corporation
does not satisfy the requirements of this
paragraph (n)(2), then this paragraph (n)(2)
will not apply to any person who receives
a distributive share or pro rata share of the
qualified conservation contribution (includ-
ing an upper-tier partnership or upper-tier
S corporation), regardless of whether the
person receiving such distributive share
or pro rata share would have satisfied the
requirements of this paragraph (n)(2) if the
person had been the one to make the quali-
fied conservation contribution.
(v) Examples. The following examples
illustrate the provisions of this paragraph
(n)(2). For the two examples in this para-
graph (n)(2)(v), assume that the excep-
tions in paragraphs (n)(3) and (4) of this
section do not apply.
(A) Example 1—(1) Facts. ABC Partnership is a
partnership for Federal income tax purposes. Since
2015, ABC Partnership’s partners have been A, an
individual, and BC Inc., an S corporation. Since
2015, BC Inc.’s shareholders have been B and C,
each of whom is an individual that is not a nonresi-
dent alien. On December 27, 2024, ABC Partnership
acquires real property. On August 29, 2025, BC Inc.
redeems half of B’s shares in BC Inc. On December
28, 2027, ABC Partnership makes a qualified conser-
vation contribution.
(2) Analysis. Pursuant to paragraph (n)(2)(iii) of
this section, BC Inc.’s redemption of some of B’s
shares is treated as an acquisition of an interest in BC
Inc. for purposes of this paragraph (n)(2). Accord-
ingly, ABC Partnership’s contribution occurred less
than three years after the latest acquisition of an
interest in a partnership or S corporation that held
an interest in ABC Partnership, the contributing part-
nership. Therefore, ABC Partnership’s contribution
fails to satisfy the requirements of this paragraph (n)
(2) and ABC Partnership must apply the provisions
of paragraphs (j) through (m) of this section to deter-
mine whether the contribution is a disallowed quali-
fied conservation contribution.
(B) Example 2—(1) Facts. LTP Partnership is a
partnership for Federal income tax purposes. Since
2017, LTP Partnership’s partners have been UTP
Partnership, a partnership for Federal income tax
purposes, and FG Inc., an S corporation. Since 2018,
UTP Partnership’s partners have been individuals D
and E, and there has been no variation in their own-
ership. Since 2019, FG Inc.’s shareholders have been
F and G, each of whom is an individual that is not a
nonresident alien. On March 15, 2024, LTP Partner-
ship acquires real property. On September 15, 2026,
D dies and D’s interest in UTP Partnership passes
to D’s estate. On March 18, 2027, LTP Partnership
makes a qualified conservation contribution. LTP
Partnership allocates all of the qualified conservation
contribution to FG Inc.
(2) Analysis. Pursuant to paragraph (n)(2)(ii) of
this section, the transfer of D’s interest in UTP Part-
nership to D’s estate is treated as an acquisition of
an interest in UTP Partnership for purposes of this
paragraph (n)(2). Accordingly, LTP Partnership’s
contribution occurred less than three years after the
latest acquisition of an interest in a partnership or S
corporation that held an interest in LTP Partnership,
the contributing partnership. Therefore, LTP Partner-
ship’s contribution fails to satisfy the requirements
of this paragraph (n)(2). Pursuant to paragraph (n)
(2)(iv) of this section, FG Inc. cannot avail itself of
this paragraph (n)(2) with respect to its allocated por-
tion of LTP Partnership’s contribution. Accordingly,
FG Inc. must apply the provisions of paragraphs (j)
through (m) of this section to determine whether its
allocated portion is a disallowed qualified conserva-
tion contribution.
(3) Exception for family partnerships
and S corporations—(i) General rule.
Paragraph (j) of this section does not apply
with respect to any qualified conservation
contribution made by a contributing part-
nership or contributing S corporation if
at least 90 percent of the interests in the
contributing partnership or contributing S
corporation are held by an individual and
members of the family of such individual
and the contributing partnership or con-
tributing S corporation meets the require-
ments of this paragraph (n)(3).
(ii) Ninety percent of the interests—(A)
Family partnerships. In the case of a con-
tributing partnership, at least 90 percent of
the interests in the contributing partnership
are held by an individual and members of
the family of such individual if, at the time
of the qualified conservation contribution,
at least 90 percent of the interests in capi-
tal and profits in such partnership are held,
directly or indirectly, by an individual and
members of the family of such individual.
(B) Family S corporations. In the case
of a contributing S corporation, at least 90
percent of the interests in the contributing
S corporation are held by an individual
and members of the family of such indi-
vidual if, at the time of the qualified con-
servation contribution, at least 90 percent
of the total value and at least 90 percent of
the total voting power of the outstanding
stock in such S corporation are held by an
individual and members of the family of
such individual.
(iii) Members of the family. For pur-
poses of this paragraph (n)(3), the term
members of the family means, with respect
to any individual—
(A) The spouse of such individual;
(B) Any individual who bears a
relationship to such individual that is
described in section 152(d)(2)(A) through
(G) of the Code;
(C) The estate of a deceased individual
who was described in paragraph (n)(3)(iii)
(A) or (B) of this section at the time of
death; and
(D) A trust all of the beneficiaries of
which are individuals described in para-
graph (n)(3)(iii)(A) or (B) of this section,
treating as beneficiaries for this purpose
those persons who currently must or may
receive income or principal from the trust
and those persons who would succeed to
the property of the trust if the trust were
to terminate immediately before the quali-
fied conservation contribution.
(iv) Anti-abuse rules—(A) Holding
period. This paragraph (n)(3) does not
apply unless at least 90 percent of the
interests in the property with respect to
which the qualified conservation contri-
bution was made were owned, directly
or indirectly, by an individual and mem-
bers of the family of that individual for
at least one year prior to the date of the
contribution. The members of the family
during that year need not be the same
members of the family that own an
interest at the time of the qualified con-
servation contribution; however, at least
one individual must own an interest for
the entire year, and at least 90 percent
of the interests in the property must be
owned, directly or indirectly, during
that year by that individual and mem-
bers of that individual’s family. Solely
for purposes of this paragraph (n)(3)(iv)
(A), section 1223(1) and (2) of the Code
do not apply in determining whether at
least ninety percent of the interests in
the property with respect to which the
qualified conservation contribution was
made were owned, directly or indirectly,

Bulletin No. 2024–30 117 July 22, 2024
by one individual and members of the
family of that individual for at least one
year prior to the date of the contribution.
This paragraph (n)(3)(iv)(A) does not
apply if the entire amount of the quali-
fied conservation contribution is limited
by section 170(e) to the contributing
partnership’s or contributing S corpo-
ration’s adjusted basis in the qualified
conservation contribution.
(B) Allocations. This paragraph (n)(3)
does not apply unless at least 90 percent
of the qualified conservation contribution
is allocated to the individual and all mem-
bers of the family who own at least 90
percent of the interests in the contributing
partnership or contributing S corporation
under paragraph (n)(3)(ii) of this section.
(v) Exception is determined at the level
of the contributing partnership or contrib-
uting S corporation. If the contributing
partnership or contributing S corporation
satisfies the requirements of this para-
graph (n)(3), then any upper-tier partner-
ship or upper-tier S corporation need not
apply paragraphs (j) through (m) of this
section and this paragraph (n) to its allo-
cated portions of such contribution. If the
contributing partnership or contributing
S corporation does not satisfy the require-
ments of this paragraph (n)(3), then the
exception in this paragraph (n)(3) will not
apply to any person who receives a distrib-
utive share or pro rata share of the quali-
fied conservation contribution (including
an upper-tier partnership or upper-tier S
corporation), regardless of whether the
person receiving such distributive share
or pro rata share would have satisfied the
requirements of this paragraph (n)(3) if
the person had been the one to make the
contribution.
(vi) Examples. The following examples
illustrate the provisions of this paragraph
(n)(3). For the two examples in this para-
graph (n)(3)(vi), assume that the excep-
tions in paragraphs (n)(2) and (4) of this
section do not apply.
(A) Example 1—(1) Facts. Individual A and A’s
sibling B acquire real property by purchase on July 5,
2024. On September 14, 2024, B transfers its inter-
est in the real property to B’s child C. On February
21, 2025, A and C transfer their interests in the real
property to AC Partnership, a partnership for Federal
income tax purposes whose only partners are A and
C. On March 18, 2025, A’s stepfather D becomes a
partner in AC Partnership in exchange for a capital
contribution. On September 15, 2025, AC Partner-
ship makes a qualified conservation contribution on
the real property. AC Partnership never had any part-
ners other than A, C, and D.
(2) Analysis. B, C, and D qualify as members of
the family with respect to A. Accordingly, as of the
time of the qualified conservation contribution, at
least 90 percent of the interests in capital and profits
of AC Partnership were owned by an individual and
members of that individual’s family. In addition, at
least 90 percent of the interests in the property with
respect to which the qualified conservation contribu-
tion was made were owned, directly and indirectly,
by A and members of A’s family for at least one year
prior to the date of the contribution. Moreover, at
least 90 percent of the contribution is allocated to A
and members of A’s family. Accordingly, the require-
ments of this paragraph (n)(3) are satisfied, and the
Disallowance Rule in section 170(h)(7)(A) and para-
graph (j) of this section does not apply.
(B) Example 2—(1) Facts. LTP Partnership is a
partnership for Federal income tax purposes whose
partners are EF Inc., an S corporation, and UTP Part-
nership, a partnership for Federal income tax pur-
poses. EF Inc. and UTP Partnership each hold a 50
percent interest in the profits and capital of LTP Part-
nership. The shareholders of EF Inc. are E and E’s
sibling F. The partners of UTP Partnership are G and
G’s child H. E and F are not related to G and H. LTP
Partnership has held real property since 2019. On
July 5, 2024, LTP Partnership distributes half of the
acres of its real property to EF Inc., and the remain-
ing acres to UTP Partnership. On October 21, 2024,
EF Inc., makes a qualified conservation contribution
on the real property it received from LTP Partner-
ship. The amount of EF Inc.’s qualified conservation
contribution is not limited by section 170(e).
(2) Analysis. F qualifies as a member of the fam-
ily with respect to E. Accordingly, as of the time of
EF Inc.’s qualified conservation contribution, EF
Inc. was owned at least 90 percent by an individual
and members of that individual’s family. In addition,
at least 90 percent of EF Inc’s qualified conserva-
tion contribution is allocated to E and members of
E’s family. However, E and members of E’s family
failed to own at least 90 percent of the property with
respect to which the qualified conservation contribu-
tion was made for at least one year prior to the date
of the contribution. In particular, G and H (who are
not members of the family with respect to E or F)
indirectly owned a 50 percent interest in the property
until July 5, 2024. Accordingly, the requirements of
this paragraph (n)(3) are not satisfied. EF Inc. must
apply the provisions of paragraphs (j) through (m)
of this section to determine whether the contribution
is a disallowed qualified conservation contribution.
If the entire amount of EF Inc.’s qualified conserva-
tion contribution had been limited by section 170(e)
to EF Inc.’s adjusted basis in the qualified conser-
vation contribution, then paragraph (n)(3)(iv)(A) of
this section would not have applied; accordingly, the
requirements of this paragraph (n)(3) would have
been satisfied, and the Disallowance Rule in section
170(h)(7)(A) and paragraph (j) of this section would
not have applied.
(4) Exception for contributions to pre-
serve certified historic structures. Para-
graph (j) of this section does not apply
to any qualified conservation contribu-
tion the conservation purpose of which is
the preservation of any building that is a
certified historic structure (as defined in
section 170(h)(4)(C)). See §1.170A-16(f)
(6) for special reporting requirements for
a contribution that meets the exception in
this paragraph (n)(4).
(o) Applicability dates—(1) In gen-
eral. Except as provided in paragraphs
(g)(4)(ii), (i), and (o)(2) of this section,
paragraphs (a) through (i) of this section
apply only to contributions made on or
after December 18, 1980. Paragraphs (j)
through (n) of this section apply to con-
tributions made after December 29, 2022.
(2) Exception. Paragraph (h)(4)(ii) of
this section applies on and after June 1,
2023.
Par. 3. Section 1.170A-16 is amended
by:
1. In paragraph (c)(3)(iv)(F), adding
the word “and” at the end of the para-
graph, and in paragraph (c)(3)(iv)(G),
removing the word “and” at the end of the
paragraph;
2. Redesignating paragraph (c)(3)(v) as
paragraph (c)(3)(vi) and adding new para-
graph (c)(3)(v);
3. In paragraph (d)(3)(vii), removing
the word “and” at the end of the paragraph;
4. Redesignating paragraph (d)(3)(viii)
as paragraph (d)(3)(x) and adding new
paragraph (d)(3)(viii);
5. Adding paragraph (d)(3)(ix);
6. Revising paragraph (f)(4);
7. Adding paragraph (f)(6); and
8. Revising paragraph (g).
The additions and revisions read as fol-
lows:
§1.170A-16 Substantiation and
reporting requirements for noncash
charitable contributions.
* * * * *
(c) * * *
(3) * * *
(v) If a number can be inserted into
any box on Form 8283 (Section A), the
number inserted in the box on Form
8283 (Section A). Alternatively, taxpay-
ers may attach a statement to the Form
8283 explaining why a number cannot be
inserted. Nothing in this paragraph (c)(3)
(v) precludes a taxpayer from both insert-
ing the number in the appropriate box on
Form 8283 (Section A) and including an

July 22, 2024 118 Bulletin No. 2024–30
attached statement explaining any addi-
tional information regarding the number.
Taxpayers may not respond to a request
for information on Form 8283 (Section
A) with nonresponsive language; for
example, by indicating that the requested
information is available upon request or
will be provided upon request. The inclu-
sion of such nonresponsive language in
response to a request for information on
Form 8283 (Section A) may be treated by
the IRS as being an incomplete filing of
Form 8283; and
* * * * *
(d) * * *
(3) * * *
(viii) In the case of a partnership or S
corporation that makes a qualified conser-
vation contribution, the sum of each ulti-
mate member’s relevant basis, computed
in accordance with §1.170A-14(j) through
(m), but only:
(A) For contributions described in
section 170(h)(7)(E) and §1.170A-14(n)
(4) (for contributions to preserve certified
historic structures), regardless of whether
they are also described in section 170(h)
(7)(C) and §1.170A-14(n)(2) (for contri-
butions made outside of the three-year
holding period) and/or section 170(h)(7)
(D) and §1.170A-14(n)(3) (for contribu-
tions made by certain family partnerships
or S corporations); and
(B) For all contributions not described
in section 170(h)(7)(E) and §1.170A-14(n)
(4), provided they are not described in
section 170(h)(7)(C) and §1.170A-14(n)
(2) (for contributions made outside of the
three-year holding period) and/or section
170(h)(7)(D) and §1.170A-14(n)(3) (for
contributions made by certain family part-
nerships or S corporations);
(ix) If a number can be inserted into
any box on Form 8283 (Section B), the
number inserted in the box on Form
8283 (Section B). Alternatively, taxpay-
ers may attach a statement to the Form
8283 explaining why a number cannot be
inserted. Nothing in this paragraph (d)(3)
(ix) precludes a taxpayer from both insert-
ing the number in the appropriate box on
Form 8283 (Section B) and including an
attached statement explaining any addi-
tional information regarding the number.
Taxpayers may not respond to a request
for information on Form 8283 (Section
B) with nonresponsive language; for
example, by indicating that the requested
information is available upon request or
will be provided upon request. The inclu-
sion of such nonresponsive language in
response to a request for information on
Form 8283 (Section B) may be treated by
the IRS as being an incomplete filing of
Form 8283; and
* * * * *
(f) * * *
(4) Partners and S corporation share-
holders—(i) Form 8283 (Section A or
Section B) must be provided to partners
and S corporation shareholders. If the
donor is a partnership or an S corporation,
the donor must provide a copy of its com-
pleted Form 8283 (Section A or Section
B) to every partner or shareholder who
receives an allocation of a charitable con-
tribution under section 170 for the prop-
erty described in Form 8283 (Section A or
Section B). Similarly, a recipient partner
that is a partnership or S corporation must
provide a copy of the donor’s completed
Form 8283 (Section A or Section B) to
each of its partners or shareholders who
receives an allocation of the charitable
contribution, and so on through any addi-
tional tiers.
(ii) Partners and S corporation share-
holders must attach Forms 8283 (Section
A or Section B) to return. A partner of a
partnership or shareholder of an S cor-
poration who receives an allocation of a
charitable contribution under section 170
for property to which paragraph (c), (d),
or (e) of this section applies must attach
to the return on which the contribution is
claimed a copy of each Form 8283 that
must be provided to them under paragraph
(f)(4)(i) or (iii) of this section.
(iii) Partners and S corporation share-
holders must file separate Forms 8283
and provide copies to any partners—(A)
In general. Subject to paragraph (f)(4)
(iii)(B) of this section, every partner of
a partnership (including a partner that
is itself a partnership or S corporation)
or shareholder of an S corporation that
receives an allocation of a charitable
contribution under section 170 for which
paragraph (c), (d), or (e) of this section
applies must complete a separate Form
8283 with any information required by
Form 8283 and the instructions to Form
8283. In the case of a partner that is itself
a partnership or S corporation, that part-
nership or S corporation must provide
a copy of its completed separate Form
8283 to every partner or shareholder who
receives an allocation of the charitable
contribution, and so on through any addi-
tional tiers. The partner or shareholder
must attach its separate Form 8283 to
the return on which the contribution is
claimed, in addition to the copy of each
Form 8283 that the partner or share-
holder is required to attach pursuant to
paragraph (f)(4)(ii) of this section.
(B) Conservation contributions. The
terms defined in §1.170A-14(j)(3) apply
for purposes of this paragraph (f)(4)(iii)
(B). In the case of a qualified conservation
contribution that is made by a partnership
or S corporation, an ultimate member’s
separate Form 8283 must include their
own relevant basis. An upper-tier part-
nership’s or upper-tier S corporation’s
separate Form 8283 must include the
sum of each of its ultimate member’s rel-
evant basis (as computed in accordance
with §1.170A-14(j) through (m)). This
paragraph (f)(4)(iii)(B) does not apply to
contributions described in section 170(h)
(7)(C) and §1.170A-14(n)(2) (for contri-
butions made outside of the three-year
holding period) or section 170(h)(7)(D)
and §1.170A-14(n)(3) (for contributions
made by certain family partnerships or
S corporations), provided that they are
not also described in section 170(h)(7)(E)
and §1.170A-14(n)(4) (for contributions
to preserve certified historic structures),
in which case this paragraph (f)(4)(iii)(B)
does apply.
* * * * *
(6) Conservation contributions by
pass-through entities preserving certified
historic structures—(i) In general. The
terms defined in §1.170A-14(j)(3) apply
for purposes of this paragraph (f)(6). For
any contribution described in paragraph
(f)(6)(ii) of this section, pursuant to sec-
tion 170(f)(19), no deduction is allowed
under section 170 or any other provision
of the Code under which deductions are
allowable to pass-through entities with
respect to such contribution unless the
contributing partnership, the contributing
S corporation, the upper-tier partnership,
or the upper-tier S corporation, respec-
tively—
(A) Includes on its return for the tax-
able year in which the contribution is

Bulletin No. 2024–30 119 July 22, 2024
made a statement that it made such a con-
tribution or received such allocated por-
tion, as described in paragraph (f)(6)(iii)
of this section; and
(B) Provides such information about
the contribution as the Secretary of the
Treasury or her delegate may require in
guidance, forms, or instructions.
(ii) Contributions to which this para-
graph (f)(6) applies. This paragraph (f)(6)
applies to any qualified conservation con-
tribution (as defined in section 170(h)(1)
and §1.170A-14):
(A) The conservation purpose of which
is preservation of a building that is a cer-
tified historic structure (as defined in sec-
tion 170(h)(4)(C));
(B) That is either:
(1) Made by a contributing partnership
(as defined in §1.170A-14(j)(3)(iii)) or
contributing S corporation (as defined in
§1.170A-14(j)(3)(iv)); or
(2) Is an allocated portion (as defined
in §1.170A-14(j)(3)(i)) of an upper-tier
partnership (as defined in §1.170A-14(j)
(3)(xi)) or upper-tier S corporation (as
defined in §1.170A-14(j)(3)(xii)); and
(C) The amount of such contribu-
tion (as defined in §1.170A-14(j)(3)(ii))
or such allocated portion (as defined in
§1.170A-14(j)(3)(i)) exceeds 2.5 times the
sum of each ultimate member’s relevant
basis (as defined in §1.170A-14(j) through
(m)).
(iii) Required information. A partnership
or S corporation satisfies the requirements
of section 170(f)(19)(A) and paragraph (f)
(6)(i) of this section by filing a completed
Form 8283, including information about
relevant basis, in accordance with section
170, the regulations under section 170, and
the instructions to Form 8283.
(g) Applicability dates—(1) In general.
Except as provided in paragraph (g)(2) of
this section, this section applies to contri-
butions made after July 30, 2018.
(2) Certain paragraphs. Paragraphs (c)
(3)(v), (d)(3)(viii) and (ix), and (f)(4) and
(6) of this section apply to taxable years
ending on or after November 20, 2023.
Par. 4. Section 1.706-0 is amended by
revising the entry for §1.706-3 to read as
follows:
§1.706-0 Table of contents.
* * * * *
§1.706–3 Items attributable to interest in
lower-tier partnership.
(a) through (c) [Reserved]
(d) Conservation contributions.
(e) Applicability date.
* * * * *
Par. 5. Section 1.706-3 is revised to
read as follows:
§1.706-3 Items attributable to interest
in lower-tier partnership.
(a) through (c) [Reserved]
(d) Conservation contributions. For
purposes of section 706(d)(3), in the
case of a qualified conservation contribu-
tion (as defined in section 170(h)(1) and
§1.170A-14(a) without regard to whether
such contribution is a disallowed quali-
fied conservation contribution within the
meaning of §1.170A-14(j)(3)(vii)) by a
partnership that is allocated to an upper-
tier partnership, the upper-tier partnership
must allocate the contribution among its
partners in accordance with their interests
in the qualified conservation contribu-
tion at the time of day at which the qual-
ified conservation contribution was made,
regardless of the general rule of section
706(d)(3). Pursuant to §1.706-4(a)(2), the
rules of §1.706-4 do not apply to alloca-
tions subject to this section.
(e) Applicability date. Paragraph (d) of
this section applies to qualified conserva-
tion contributions made after December
29, 2022, and in partnership taxable years
ending after December 29, 2022.
Par. 6. Section 1.706-4 is amended by:
1. Adding a reserved paragraph (e)(2)
(xii);
2. Adding paragraph (e)(2)(xiii); and
3. Revising paragraph (e)(3).
The additions and revision read as fol-
lows:
§1.706-4 Determination of distributive
share when a partner’s interest varies.
* * * * *
(e) * * *
(2) * * *
(xii) [Reserved]
(xiii) Applicable for partnership tax-
able years ending after December 29,
2022, any qualified conservation contribu-
tion (as defined in section 170(h)(1) and
§1.170A-14(a) without regard to whether
such contribution is a disallowed quali-
fied conservation contribution within the
meaning of §1.170A-14(j)(3)(vii)) made
after December 29, 2022.
(3) Small item exception—(i) In general.
A partnership may treat an item described in
paragraph (e)(2) of this section (except for
an item described in paragraph (e)(2)(xiii)
of this section) as other than an extraordi-
nary item for purposes of this paragraph
(e) if, for the partnership’s taxable year the
total of all items in the particular class of
extraordinary items (as enumerated in para-
graphs (e)(2)(i) through (xii) of this section,
for example, all tort or similar liabilities, but
in no event counting an extraordinary item
more than once) is less than five percent of
the partnership’s gross income, including
tax-exempt income described in section
705(a)(1)(B), in the case of income or gain
items, or gross expenses and losses, includ-
ing section 705(a)(2)(B) expenditures, in
the case of losses and expense items; and
the total amount of the extraordinary items
from all classes of extraordinary items
amounting to less than five percent of the
partnership’s gross income, including
tax-exempt income described in section
705(a)(1)(B), in the case of income or gain
items, or gross expenses and losses, includ-
ing section 705(a)(2)(B) expenditures, in
the case of losses and expense items, does
not exceed $10 million in the taxable year,
determined by treating all such extraordi-
nary items as positive amounts.
(ii) Applicability date. This paragraph
(e)(3) applies to partnership taxable years
ending after December 29, 2022. For
partnership taxable years ending before
December 30, 2022, see paragraph (e)(3)
of this section contained in 26 CFR part 1,
as revised April 1, 2024.
* * * * *
Douglas W. O’Donnell,
Deputy Commissioner.
Approved: June 15, 2024.
Aviva R. Aron-Dine,
Acting Assistant Secretary of
the Treasury (Tax Policy).
(Filed by the Office of the Federal Register June 24,
2024, 8:45 a.m., and published in the issue of the
Federal Register for June 28, 2024, 89 FR 54284)

July 22, 2024 120 Bulletin No. 2024–30
Part III
2024 Marginal Production
Rates
Notice 2024-58
This notice announces the applicable
percentage under § 613A of the Internal
Revenue Code to be used in determining
percentage depletion for marginal proper-
ties for the 2024 calendar year.
Section 613A(c)(6)(C) defines the term
“applicable percentage” for purposes of
determining percentage depletion for oil
and gas produced from marginal properties.
The applicable percentage is the percent-
age (not greater than 25 percent) equal to
the sum of 15 percent, plus one percentage
point for each whole dollar by which $20
exceeds the reference price (determined
under § 45K(d)(2)(C)) for crude oil for the
calendar year preceding the calendar year
in which the taxable year begins. The ref-
erence price determined under § 45K(d)(2)
(C) for the 2023 calendar year is $76.10.
The following table contains the appli-
cable percentages for marginal production
for taxable years beginning in calendar
years 1991 through 2024.
Notice 2024-58
APPLICABLE PERCENTAGE FOR MARGINAL PRODUCTION
Calendar YearApplicable Percentage
1991 15 percent
1992 18 percent
1993 19 percent
1994 20 percent
1995 21 percent
1996 20 percent
1997 16 percent
1998 17 percent
1999 24 percent
2000 19 percent
2001 15 percent
2002 15 percent
2003 15 percent
2004 15 percent
2005 15 percent
2006 15 percent
2007 15 percent
2008 15 percent
2009 15 percent
2010 15 percent
2011 15 percent
2012 15 percent
2013 15 percent
2014 15 percent
2015 15 percent
2016 15 percent
2017 15 percent
2018 15 percent
2019 15 percent
2020 15 percent
2021 15 percent
2022 15 percent
2023 15 percent
2024 15 percent
The principal author of this notice
is Christopher Vlcek of the Office of Asso-
ciate Chief Counsel (Passthroughs and
Special Industries). For further information
regarding this notice contact Mr. Vlcek
at (202) 317-4743 (not a toll-free number).

Bulletin No. 2024–30 121 July 22, 2024
NOTE. This revenue procedure will be reproduced as the next revision of IRS Publication 1179, General Rules and Specifications for Substitute Forms 1096, 1098,
1099, 5498, and Certain Other Information Returns.
Forms and instructions. (Also, Part 1, sections 101, 162(f), 170, 199A, 220, 223, 401(a), 403(a), 403(b), 408, 408A, 457(b), 529, 529A, 530, 853A, 892, 1400Z-1,
1400Z-2, 1441, 6041, 6041A, 6042, 6043, 6044, 6045, 6047, 6049, 6050A, 6050B, 6050D, 6050E, 6050H, 6050J, 6050N, 6050P, 6050Q, 6050R, 6050S, 6050U,
6050W, 6050X, 6050Y, 6071, 1.402A-2, 1.408-5, 1.408-7, 1.408-8, 1.408A-7, 1.1441-1 through 1.1441-5, 1.1471-4, 1.6041-1, 1.6042-2, 1.6042-4, 1.6043-4, 1.6044-
2, 1.6044-5, 1.6045-1, 1.6045-2, 1.6045-4, 1.6047-1, 1.6047-2, 1.6049-4, 1.6049-6, 1.6049-7, 1.6050A-1, 1.6050B-1, 1.6050D-1, 1.6050E-1, 1.6050H-1, 1.6050H-2,
1.6050J-1T, 1.6050N-1, 1.6050P-1, 1.6050S-1, 1.6050S-3, 1.6050W-1, 1.6050W-2, 1.6050X-1, 1.6050Y-1, 1.6050Y-2, and 1.6050Y-3.)
Rev. Proc. 2024-29
TABLE OF CONTENTS
Part 1 – GENERAL INFORMATION
Section 1.1 – Overview of Revenue Procedure 2024-29 / What’s New ..........................................122
Section 1.2 – Definitions ..............................................................................126
Section 1.3 – General Requirements for Acceptable Substitute Forms 1096, 1097-BTC, 1098, 1099, 3921,
3922, 5498, W-2G, and 1042-S ..............................................................126
Part 2 –
SPECIFICATIONS FOR SUBSTITUTE FORMS 1096 AND COPIES A OF FORMS 1098, 1099,
3921, 3922, AND 5498 (ALL FILED WITH THE IRS)
Section 2.1 – Specifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .130
Section 2.2 – Instructions for Preparing Paper Forms That Will Be Filed With the IRS .............................135
Part 3 – SPECIFICATIONS FOR SUBSTITUTE FORM W-2G (FILED WITH THE IRS)
Section 3.1 – General ................................................................................137
Section 3.2 – Specifications for Copy A of Form W-2G ......................................................137
Part 4 – SUBSTITUTE STATEMENTS TO FORM RECIPIENTS AND FORM RECIPIENT COPIES
Section 4.1 – Specifications. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .138
Section 4.2 – Composite Statements .....................................................................142
Section 4.3 – Additional Information for Substitute and Composite Forms 1099-B ................................144
Section 4.4 – Required Legends ........................................................................144
Section 4.5 – Miscellaneous Instructions for Copies B, C, D, 1, and 2 ..........................................146
Section 4.6 – Electronic Delivery of Recipient Statements ...................................................148
Part 5 – ADDITIONAL INSTRUCTIONS FOR SUBSTITUTE FORMS 1097- BTC, 1098, 1099, 5498,
W-2G, AND 1042-S
Section 5.1 – Paper Substitutes for Form 1042-S ...........................................................149
Section 5.2 – OMB Requirements for All Forms in This Revenue Procedure .....................................151
Section 5.3 – Ordering Forms and Instructions .............................................................152
Section 5.4 – Effect on Other Revenue Procedures ..........................................................152
Part 6 – EXHIBITS
Section 6.1 – Exhibits of Forms in This Revenue Procedure ..................................................153

July 22, 2024 122 Bulletin No. 2024–30
Part 1
General Information
Section 1.1 – Overview of Revenue Procedure 2024-29 / What’s New
1.1.1
Purpose
The purpose of this revenue procedure is to set forth the 2024 requirements for:
• Using official Internal Revenue Service (IRS) forms to file information returns with the IRS,
• Preparing acceptable substitutes of the official IRS forms to file information returns with the
IRS, and
• Using official or acceptable substitute forms to furnish information to recipients.
1.1.2
Which Forms Ar
e Covered?
This revenue procedure contains specifications for the following information returns.
FormTitle
1096Annual Summary and Transmittal of U.S. Information Returns
1097-BTCBond Tax Credit
1098Mortgage Interest Statement
1098-CContributions of Motor Vehicles, Boats, and Airplanes
1098-EStudent Loan Interest Statement
1098-FFines, Penalties, and Other Amounts
1098-MAMortgage Assistance Payments
1098-QQualifying Longevity Annuity Contract Information
1098-TTuition Statement
1099-AAcquisition or Abandonment of Secured Property
1099-BProceeds From Broker and Barter Exchange Transactions
1099-CCancellation of Debt
1099-CAPChanges in Corporate Control and Capital Structure
1099-DIVDividends and Distributions
1099-GCertain Government Payments
1099-HHealth Coverage Tax Credit (HCTC) Advance Payments
1099-INTInterest Income
1099-KPayment Card and Third Party Network Transactions
1099-LSReportable Life Insurance Sale
1099-LTCLong-Term Care and Accelerated Death Benefits
1099-MISCMiscellaneous Information

Bulletin No. 2024–30 123 July 22, 2024
FormTitle
1099-NECNonemployee Compensation
1099-OIDOriginal Issue Discount
1099-PATRTaxable Distributions Received From Cooperatives
1099-QPayments From Qualified Education Programs (Under Sections 529 and 530)
1099-QADistributions From ABLE Accounts
1099-RDistributions From Pensions, Annuities, Retirement or Profit-Sharing Plans,
IRAs, Insurance Contracts, etc.
1099-SProceeds From Real Estate Transactions
1099-SADistributions From an HSA, Archer MSA, or Medicare Advantage MSA
1099-SBSeller’s Investment in Life Insurance Contract
3921Exercise of an Incentive Stock Option Under Section 422(b)
3922Transfer of Stock Acquired Through an Employee Stock Purchase Plan Under
Section 423(c)
5498IRA Contribution Information
5498-ESACoverdell ESA Contribution Information
5498-QAABLE Account Contribution Information
5498-SAHSA, Archer MSA, or Medicare Advantage MSA Information
W-2GCertain Gambling Winnings
1042-SForeign Person’s U.S. Source Income Subject to Withholding
1.1.3
Scope
For purposes of this revenue procedure, a substitute form or statement is one that is not published
by the IRS. For a substitute form or statement to be acceptable to the IRS, it must conform to the
official form or the specifications outlined in this revenue procedure. Do not submit any substitute
forms or statements listed above to the IRS for approval. Privately published forms may not state,
“This is an IRS approved form.”
Filers making payments to certain recipients during a calendar year are required by the Internal
Revenue Code (the Code) to file information returns with the IRS for these payments. These filers
must also provide this information to their recipients. In some cases, this also applies to payments
received. See Part 4 for specifications that apply to recipient statements (generally Copy B).
In general, section 6011 of the Code authorizes the Secretary of Treasury to publish regulations
that require filers to file information returns according to those regulations and the corresponding
forms and instructions. A filer who is required to file 10 or more information returns during a
calendar year must file those returns electronically. See Electronic filing of returns, later, for more
information.
Caution. Financial institutions that are required to report payments made under chapter 3 or 4
must file Forms 1042-S electronically, regardless of the number of returns required to be filed.
Note. If you file electronically, do not file the same returns on paper.

July 22, 2024 124 Bulletin No. 2024–30
Filers required to fi le fewer than 10 information returns during a calendar year are encouraged to
fi le the information returns electronically. See the requirements for fi ling information returns (and
providing a copy to a payee) in the current General Instructions for Certain Information Returns
and the current Instructions for Form 1042-S. In addition, see the current revision of Pub. 1220,
Specifi cations for Electronic Filing of Forms 1097, 1098, 1099, 3921, 3922, 5498, and W-2G, for
electronic fi ling through the IRS Filing Information Returns Electronically (FIRE) system.
1.1.4
For More Information
The IRS prints and provides the forms on which various payments must be reported. See Section
5.3 for ordering forms and instructions. Alternately, fi lers may prepare substitute copies of these
IRS forms and use such forms to report payments to the IRS.
The Internal Revenue Service/Technical Service Operation (IRS/TSO) maintains a
centralized customer service call site to answer questions related to information
returns (Forms W-2, W-3, W-2c, W-3c, 1099, 1096, etc.). You can reach the call site
series, 1096,
at 866-455-7438 (toll free) or outside the United States at 304-263-8700 (not a toll-
free number). Deaf or hard-of-hearing customers may call any of our toll-free numbers using their
choice of relay service.
Questions regarding the fi ling of information returns and comments/suggestions
regarding this publication can be emailed to fi re@irs.gov. When you send emails
concerning specifi c fi le information, include the company name and the electronic

fi le name or Transmitter Control Code (TCC). Do not include taxpayer identifi cation
numbers (TINs) or attachments in email correspondence because electronic mail is
not secure.
The IRS/TSO does not process information returns which are fi led on paper forms.
CAUT
!
See Pub. 1220 for information on waivers and extensions of time.
ION
For other tax information related to business returns or accounts, call 800-829-4933.
Deaf or hard-of-hearing customers may call any of our toll-free numbers using their
choice of relay service.
questions

Further information impacting Pub. 1179, such as issues arising after its fi nal release,
TIP
will be posted on IRS.gov at IRS.gov/Pub1179.

The following changes have been made to this year’s revenue procedure. For further information
about each form listed below, see the separate reporting instructions.
Removal of fi ler copy. In an ongoing process to reduce fi ler burden, we are removing the fi ler
copy and instructions for the fi ler on forms.
Form 1099-H. The Health Coverage Tax Credit expired on December 31, 2021. The form is listed
for reference purposes only.
Exhibits. All of the exhibits in this publication were updated to include all of the 2024 revisions
of those forms that have been revised.
3

1.1.4
For More
Information

1.1.5
What’s New

The IRS prints and provides the forms on which various payments must be
reported. See Section 5.3, later, for ordering forms and instructions. Alternately,
filers may prepare substitute copies of these IRS forms and use such forms to
report payments to the IRS.
The Internal Revenue Service/Information Returns Branch (IRS/IRB)
maintains a centralized customer service call site to answer questions
related to information returns (Forms W-2, W-3, W-2c, W-3c, 1099
etc.). You can reach the call site at 866-455-7438 (toll-free) or
outside the United States 304-263-8700 (not a toll-free number). Persons with a
hearing or speech disability with access to TTY/TDD equipment can call
304-579-4827 (not a toll-free number).

You may also send questions to the call site via the Internet at
mccirp@irs.gov.

IRS/IRB does not process information returns which are filed on paper
forms. See Publication 1220 for information on waivers and extensions
of time.
For other tax information related to business returns or accounts, call
800-829-4933. Persons with hearing or speech disabilities with access
to TTY/TDD equipment can call 800-829-4059 to ask tax account
questions or to order forms and publications.

Further information impacting Publication 1179, such as issues
arising after its final release, will be posted on IRS.gov at IRS.gov/
pub1179.

The following changes have been made to this year’s revenue procedure. For
further information about each form listed below, see the separate reporting
instructions.
Electronic filing of returns. The Taxpayer First Act of 2019, enacted July 1,
2019, authorized the Department of the Treasury and the IRS to issue
regulations that reduce the 250-return requirement for 2022 tax returns. If final
regulations are issued and effective for 2022 tax returns required to be filed in
2023, we will post an article at IRS.gov explaining the change. Until final
regulations are issued, however, the number remains at 250, as reflected in these
instructions.
Electronic filing of Forms 1099. Under Section 2102 of the Taxpayer First Act
the IRS is developing an Internet portal that will allow taxpayers to
electronically file Forms 1099 after December 31, 2022 , as an alternative to
using the Filing Information Returns Electronically (FIRE) system. See Part F
in the General Instructions for Certain Information Returns for 2022 or go to
IRS.gov for additional information and updates.
Form 1099-H. The Health Coverage Tax Credit expired on December 31,
2021. The form is listed for reference purposes only.

CAUTION
!
TIP
3

1.1.4
For More
Information

1.1.5
What’s New

The IRS prints and provides the forms on which various payments must be
reported. See Section 5.3, later, for ordering forms and instructions. Alternately,
filers may prepare substitute copies of these IRS forms and use such forms to
report payments to the IRS.
The Internal Revenue Service/Information Returns Branch (IRS/IRB)
maintains a centralized customer service call site to answer questions
related to information returns (Forms W-2, W-3, W-2c, W-3c, 1099
series, 1096, etc.). You can reach the call site at 866-455-7438 (toll-free) or
outside the United States 304-263-8700 (not a toll-free number). Persons with a
hearing or speech disability with access to TTY/TDD equipment can call
304-579-4827 (not a toll-free number).

You may also send questions to the call site via the Internet at
mccirp@irs.gov
.
IRS/IRB does not process information returns which are filed on paper
for
ms. See Publication 1220 for information on waivers and extensions
of time.
For other tax information related to business returns or accounts, call
800-829-4933. Persons with hearing or speech disabilities with access
to TTY/TDD equipment can call 800-829-4059 to ask tax account
questions or to order forms and publications.

Further information impacting Publication 1179, such as issues
arising after its final release, will be posted on IRS.gov at IRS.gov/
pub1179.

The following changes have been made to this year’s revenue procedure. For
further information about each form listed below, see the separate reporting
instructions.
Electronic filing of returns. The Taxpayer First Act of 2019, enacted July 1,
2019, authorized the Department of the Treasury and the IRS to issue
regulations that reduce the 250-return requirement for 2022 tax returns. If final
regulations are issued and effective for 2022 tax returns required to be filed in
2023, we will post an article at IRS.gov explaining the change. Until final
regulations are issued, however, the number remains at 250, as reflected in these
instructions.
Electronic filing of Forms 1099. Under Section 2102 of the Taxpayer First Act
the IRS is developing an Internet portal that will allow taxpayers to
electronically file Forms 1099 after December 31, 2022 , as an alternative to
using the Filing Information Returns Electronically (FIRE) system. See Part F
in the General Instructions for Certain Information Returns for 2022 or go to
IRS.gov for additional information and updates.
Form 1099-H. The Health Coverage Tax Credit expired on December 31,
2021. The form is listed for reference purposes only.

CAUTION
!
TIP
3

1.1.4
For More
Information

1.1.5
What’s New

The IRS prints and provides the forms on which various payments must be
reported. See Section 5.3, later, for ordering forms and instructions. Alternately,
filers may prepare substitute copies of these IRS forms and use such forms to
report payments to the IRS.
The Internal Revenue Service/Information Returns Branch (IRS/IRB)
maintains a centralized customer service call site to answer questions
related to information returns (Forms W-2, W-3, W-2c, W-3c, 1099
series, 1096, etc.). You can reach the call site at 866-455-7438 (toll-free) or
outside the United States 304-263-8700 (not a toll-free number). Persons with a
hearing or speech disability with access to TTY/TDD equipment can call
304-579-4827 (not a toll-free number).

You may also send questions to the call site via the Internet at
mccirp@irs.gov.

IRS/IRB does not process information returns which are filed on paper
forms. See Publication 1220 for information on waivers and extensions
of time.
For other tax information related to business returns or accounts, call
800-829-4933. Persons with hearing or speech disabilities with access
to TTY/TDD equipment can call 800-829-4059 to ask tax account
questions or to order forms and publications.

Further information impacting Publication 1179, such as issues
arising after its final release, will be posted on IRS.gov at IRS.gov/
pub1179.

The following changes have been made to this year’s revenue procedure. For
further information about each form listed below, see the separate reporting
instructions.
Electronic filing of returns. The Taxpayer First Act of 2019, enacted July 1,
2019, authorized the Department of the Treasury and the IRS to issue
regulations that reduce the 250-return requirement for 2022 tax returns. If final
regulations are issued and effective for 2022 tax returns required to be filed in
2023, we will post an article at IRS.gov explaining the change. Until final
regulations are issued, however, the number remains at 250, as reflected in these
instructions.
Electronic filing of Forms 1099. Under Section 2102 of the Taxpayer First Act
the IRS is developing an Internet portal that will allow taxpayers to
electronically file Forms 1099 after December 31, 2022 , as an alternative to
using the Filing Information Returns Electronically (FIRE) system. See Part F
in the General Instructions for Certain Information Returns for 2022 or go to
IRS.gov for additional information and updates.
Form 1099-H. The Health Coverage Tax Credit expired on December 31,
2021. The form is listed for reference purposes only.

TIP
3

1.1.4
For More
Information

1.1.5
What’s New

The IRS prints and provides the forms on which various payments must be
reported. See Section 5.3, later, for ordering forms and instructions. Alternately,
filers may prepare substitute copies of these IRS forms and use such forms to
report payments to the IRS.
The Internal Revenue Service/Information Returns Branch (IRS/IRB)
maintains a centralized customer service call site to answer questions
related to information returns (Forms W-2, W-3, W-2c, W-3c, 1099
series, 1096, etc.). You can reach the call site at 866-455-7438 (toll-free) or
outside the United States 304-263-8700 (not a toll-free number). Persons with a
hearing or speech disability with access to TTY/TDD equipment can call
304-579-4827 (not a toll-free number).

You may also send questions to the call site via the Internet at
mccirp@irs.gov.

IRS/IRB does not process information returns which are filed on paper
forms. See Publication 1220 for information on waivers and extensions
of time.
For other tax information related to business returns or accounts, call
800-829-4933. Persons with hearing or speech disabilities with access
to TTY/TDD equipment can call 800-829-4059 to ask tax account
or to order forms and publications.

Further information impacting Publication 1179, such as issues
arising after its final release, will be posted on IRS.gov at IRS.gov/
pub1179.

The following changes have been made to this year’s revenue procedure. For
further information about each form listed below, see the separate reporting
instructions.
Electronic filing of returns. The Taxpayer First Act of 2019, enacted July 1,
2019, authorized the Department of the Treasury and the IRS to issue
regulations that reduce the 250-return requirement for 2022 tax returns. If final
regulations are issued and effective for 2022 tax returns required to be filed in
2023, we will post an article at IRS.gov explaining the change. Until final
regulations are issued, however, the number remains at 250, as reflected in these
instructions.
Electronic filing of Forms 1099. Under Section 2102 of the Taxpayer First Act
the IRS is developing an Internet portal that will allow taxpayers to
electronically file Forms 1099 after December 31, 2022 , as an alternative to
using the Filing Information Returns Electronically (FIRE) system. See Part F
in the General Instructions for Certain Information Returns for 2022 or go to
IRS.gov for additional information and updates.
Form 1099-H. The Health Coverage Tax Credit expired on December 31,
2021. The form is listed for reference purposes only.

CAUTION
!
TIP
3

1.1.4
For More
Information

1.1.5
What’s New

The IRS prints and provides the forms on which various payments must be
reported. See Section 5.3, later, for ordering forms and instructions. Alternately,
filers may prepare substitute copies of these IRS forms and use such forms to
report payments to the IRS.
The Internal Revenue Service/Information Returns Branch (IRS/IRB)
maintains a centralized customer service call site to answer questions
related to information returns (Forms W-2, W-3, W-2c, W-3c, 1099
series, 1096, etc.). You can reach the call site at 866-455-7438 (toll-free) or
outside the United States 304-263-8700 (not a toll-free number). Persons with a
hearing or speech disability with access to TTY/TDD equipment can call
304-579-4827 (not a toll-free number).

You may also send questions to the call site via the Internet at
mccirp@irs.gov.

IRS/IRB does not process information returns which are filed on paper
forms. See Publication 1220 for information on waivers and extensions
of time.
For other tax information related to business returns or accounts, call
800-829-4933. Persons with hearing or speech disabilities with access
to TTY/TDD equipment can call 800-829-4059 to ask tax account
questions or to order forms and publications.
Further information impacting Publication 1179, such as issues
ari
sing after its final release, will be posted on IRS.gov at IRS.gov/
pub1179.
The following changes have been made to this year’s revenue procedure. For
f
urther information about each form listed below, see the separate reporting
instructions.
Electronic filing of returns. The Taxpayer First Act of 2019, enacted July 1,
2019, authorized the Department of the Treasury and the IRS to issue
regulations that reduce the 250-return requirement for 2022 tax returns. If final
regulations are issued and effective for 2022 tax returns required to be filed in
2023, we will post an article at IRS.gov explaining the change. Until final
regulations are issued, however, the number remains at 250, as reflected in these
instructions.
Electronic filing of Forms 1099. Under Section 2102 of the Taxpayer First Act
the IRS is developing an Internet portal that will allow taxpayers to
electronically file Forms 1099 after December 31, 2022 , as an alternative to
using the Filing Information Returns Electronically (FIRE) system. See Part F
in the General Instructions for Certain Information Returns for 2022 or go to
IRS.gov for additional information and updates.
Form 1099-H. The Health Coverage Tax Credit expired on December 31,
2021. The form is listed for reference purposes only.

CAUTION
!
1.1.5
What’s New

Bulletin No. 2024–30 125 July 22, 2024
Editorial changes. We made editorial changes throughout, including updated references.
Redundancies were eliminated as much as possible.
Available Instructions
In addition to the general instructions, which contain general information concerning Forms 1096,
1097, 1098, 1099, 3921, 3922, 5498, and W-2G, specific form instructions are provided separately.
Use the instructions to prepare acceptable substitutes of the official IRS forms to file information
returns with the IRS.
• Instructions for Form 1097-BTC.
• Instructions for Form 1098.
• Instructions for Form 1098-C.
• Instructions for Forms 1098-E and 1098-T.
• Instructions for Form 1098-F.
• Instructions for Form 1098-Q.
• Instructions for Forms 1099-A and 1099-C.
• Instructions for Form 1099-B.
• Instructions for Form 1099-CAP.
• Instructions for Form 1099-DIV.
• Instructions for Form 1099-G.
• Instructions for Form 1099-H.
• Instructions for Forms 1099-INT and 1099-OID.
• Instructions for Form 1099-K.
• Instructions for Form 1099-LS.
• Instructions for Form 1099-LTC.
• Instructions for Forms 1099-MISC and 1099-NEC.
• Instructions for Form 1099-PATR.
• Instructions for Form 1099-Q.
• Instructions for Forms 1099-QA and 5498-QA.
• Instructions for Forms 1099-R and 5498.
• Instructions for Form 1099-S.
• Instructions for Form 1099-SB.
• Instructions for Forms 3921 and 3922.
• Instructions for Form 5498-ESA.
• Instructions for Forms W-2G and 5754.

July 22, 2024 126 Bulletin No. 2024–30
You can also obtain the latest developments for each of the forms and instructions listed here by
going to their information pages at IRS.gov. See the separate instructions for each form on the
webpage via the link.
Section 1.2 – Definitions
1.2.1
Form Recipient
Form recipient means the person to whom you are required by law to furnish a copy of the
official form or information statement. The form recipient may be referred to by different names
on various Forms 1099 and related forms (beneficiary, borrower, debtor, donor, employee, filer,
homeowner, insured, participant, payee, payer, payer/borrower, payment recipient, policyholder,
seller, shareholder, student, transferor, or, in the case of Form W-2G, the winner). See Section
1.3.4.
1.2.2
Filer
Filer means the person or organization required by law to file with the IRS a form listed in Section
1.1.2. A filer may be a payer, creditor, payment settlement entity, recipient of mortgage or student
loan interest payments, educational institution, broker, barter exchange, or person reporting real
estate transactions; a trustee or issuer of any educational or ABLE Act savings account, individual
retirement arrangement, or medical savings account; a lender who acquires an interest in secured
property or who has reason to know that the property has been abandoned; a corporation reporting
a change in control and capital structure or transfer of stock to an employee; certain donees of
motor vehicles, boats, and airplanes; or an acquirer or issuer of a life insurance contract.
1.2.3
Substitute Form
Substitute form means a paper substitute of Copy A of an official form listed in Section 1.1.2 that
completely conforms to the provisions in this revenue procedure.
1.2.4
Substitute Form Recipient
Statement (Recipient
Statement)
Substitute form recipient statement means a paper or electronic statement of the information
reported on a form listed in Section 1.1.2. For the remainder of this revenue procedure, we
will refer to this as a “recipient statement.” This statement must be furnished to a person (form
recipient), as defined under the applicable provisions of the Code and the applicable regulations.
1.2.5
Composite Substitute
Statement
Composite substitute statement means one in which two or more required statements (for example,
Forms 1099-INT and 1099-DIV) are furnished to the recipient on one document. However, each
statement must be designated separately and must contain all the requisite Form 1099 information
except as provided under Section 4.2. A composite statement may not be filed with the IRS.
Section 1.3 – General Requirements for Acceptable Substitute Forms 1096, 1097-BTC, 1098, 1099, 3921, 3922, 5498, W-2G,
and 1042-S
1.3.1
Intr
oduction
Paper substitutes for Form 1096 and Copy A of Forms 1097-BTC, 1098, 1099, 3921, 3922, 5498,
W-2G, and 1042-S that completely conform to the specifications listed in this revenue procedure

Bulletin No. 2024–30 127 July 22, 2024
may be privately printed and filed as returns with the IRS. The reference to the Department of the
Treasury – Internal Revenue Service should be included on all such forms.
If you are uncertain of any specification and want it clarified, you may submit a letter citing the
specification, stating your understanding and interpretation of the specification, and enclosing an
example of the form (if appropriate) to:
Internal Revenue Service
Attn: Substitute Forms Program
C:DC:TS:CAR:MP:P:TP:TP
ATSC
4800 Buford Highway
Mail Stop 061-N
Chamblee, GA 30341
Note. Allow at least 30 days for the IRS to respond.
You may also contact the Substitute Forms Program via email at substituteforms@irs.gov. Please
enter “Substitute Forms” on the subject line.
Note. Do not send completed forms to the Substitute Forms Program via email or mail as they are
unable to process those forms. Any examples/samples of substitute forms sent to the Substitute
Forms Program should not contain taxpayer information.
Forms 1096, 1097-BTC, 1098, 1099, 3921, 3922, 5498, W-2G, and 1042-S are subject to annual
review and possible change. Therefore, filers are cautioned against overstocking supplies of
privately printed substitutes.
1.3.2
Logos, Slogans, and
Advertisements
Some Forms 1097-BTC, 1098, 1099, 3921, 3922, 5498, W-2G, and 1042-S that include logos,
slogans, and advertisements may not be recognized as important tax documents. A payee may
not recognize the importance of the payee copy for tax reporting purposes due to the use of
logos, slogans, and advertisements. Accordingly, the IRS has determined that logos, slogans, and
advertising are not allowed on the payee copies of the above forms, on Copy A filed with the
IRS, or on Form 1096, or on an envelope or enclosed in an envelope containing any of those
documents, with the following exceptions.
• The exact name of the payer, broker, or agent, primary trade name, trademark, service mark,
or symbol of the payer, broker, or agent, an embossment or watermark on the information
return and payee copies that is a representation of the name, a primary trade name, trade-
mark, service mark, or symbol of the payer, broker, or agent, that is:
– Presented in any typeface, font, stylized fashion, or print color normally used by the
payer, broker, or agent, and used in a non-intrusive manner; and
– As long as these items do not materially interfere with the ability of the recipient to rec-
ognize, understand, and use the tax information on the payee copies.
• The IRS e-file logo on the IRS official payee copies may be included, but it is not required, on
any of the substitute form copies.
• Logos and slogans may be used on permissible enclosures, such as a check or account state-
ment, other than information returns and payee copies.

July 22, 2024 128 Bulletin No. 2024–30
The information return and payee copies must clearly identify the payer’s name associated with its
employer identification number (EIN).
If you have comments about the restrictions on including logos, slogans, and advertising on
information returns and payee copies, send your comments to:
Internal Revenue Service
Attn: Substitute Forms Program
C:DC:TS:CAR:MP:P:TP:TP
ATSC
4800 Buford Highway
Mail Stop 061-N
Chamblee, GA 30341
or email them to substituteforms@irs.gov.
Note. Do not send completed forms to the Substitute Forms Program via email or mail as they are
unable to process those forms. Any examples/samples of substitute forms sent to the Substitute
Forms Program should not contain taxpayer information.
1.3.3
Copy
A Specifications
Proposed substitutes of Copy A must be exact replicas of the official IRS form with respect to
layout and content. Proposed substitutes for Copy A that do not conform to the specifications in
this revenue procedure are not acceptable.
Further, if you file such forms with the IRS, you may be subject to a penalty for failure to file a
correct information return under section 6721 of the Code. The amount of the penalty is based on
when you file the correct information return.
Penalties. The amounts of the penalty for returns required to be filed in 2024 is shown under
Penalties in part O of the 2024 General Instructions for Certain Information Returns.
1.3.4
Copy B and Copy C
Specifications
Copy B and Copy C of the following forms must contain the information in Part 4 to be considered
a “statement” or “official form” under the applicable provisions of the Code. The format of this
information is at the discretion of the filer with the exception of the location of the tax year,
the form number, the form name, and the information for composite Form 1099 statements, as
outlined under Section 4.2.

Bulletin No. 2024–30 129 July 22, 2024
Copy B of the forms below is for the following recipients.
FormRecipient
1098For Payer/Borrower
1098-CFor Donor
1098-E; 1099-AFor Borrower
1098-FFor Payer
1098-MAFor Homeowner
1098-QFor Participant
1098-TFor Student
1099-CFor Debtor
1099-CAPFor Shareholder
1099-KFor Payee
1099-LSFor Payment Recipient
1099-LTCFor Policyholder
1099-R; W-2GCopy B may be required to be attached to the filer’s federal
income tax return.
1099-SFor Transferor
1099-SBFor Seller
All remaining Forms 1099;
1097-BTC; 1042-S
For Recipient
3921; 3922For Employee
5498; 5498-SAFor Participant
5498-QA; 5498-ESAFor Beneficiary
Copy C of the forms below is for the following recipients.
FormRecipient
1097-BTCFor Payer
1098For Recipient/Lender
1098-CFor Donor’s Records
1042-SFor Recipient
1098-F; 1098-MAFor Filer
1098-QFor Issuer
1099-CAP; 3921; 3922For Corporation
1099-LTCFor Insured
1099-QAFor Payer
1099-RFor Recipient’s Records
All other Forms 1099
See Section 4.5.2.
W-2GFor Winner’s Records
Note. On Copy C of Form 1099-LTC, you may reverse the locations of the policyholder’s and the
insured’s name, street address, city, state, and ZIP code for easier mailing.

July 22, 2024 130 Bulletin No. 2024–30
Part 2
Specifications for Substitute Forms 1096 and Copies A of Forms 1098, 1099, 3921, 3922,
and 5498 (All Filed With the IRS)
Section 2.1 – Specifications
2.1.1
Online Fillable Forms
Due to the very low volume of paper Forms 1097-BTC, 1098-C, 1098-F, 1098-MA, 1099-A,
1099-CAP, 1099-LTC, 1099-Q, 1099-QA, 1099-SA, 3922, 5498-ESA, 5498-QA, and 5498-SA
received and processed by the IRS each year, these forms have been converted to fillable online
PDFs.
Note. The instructions for substitute Forms 1042-S, also available in a fillable online format, are
found separately in Part 5.
These forms in their fillable formats can be found at IRS.gov/FormsPubs.
All the instructions regarding the substitute forms found in Part 1, and Sections 2.1.2, 2.1.7, 2.1.9,
and 2.1.10, and the remainder of this publication, unless specified differently immediately below,
remain in effect if you are going to produce the online fillable forms as paper or online substitute
forms.
• Copy A of privately printed substitutes of the forms listed above must be exact replicas of
the official forms with respect to layout and content. Use the official form, found on IRS.gov,
printed actual size on an 8½ inch by 11 inch sheet of paper. The forms will print one to a
page.
• All printing must be in high quality nongloss black ink.
• Paper for Copy A must be white chemical wood bond, or equivalent, 20 pounds (basis 17 x
22-500), plus or minus 5% (0.05); or offset book paper, 50 pounds (basis 25 x 38-500). No
optical brighteners may be added to the pulp or paper during manufacture. The paper must
consist of principally bleached chemical wood pulp or recycled printed paper. It must also
be suitably sized to accept ink without feathering.
Note. If you want to print the forms as they formerly appeared to save paper, with the exception of
Forms 1097-BTC (printed 2-to-a-page) and 1098-C (single-form page), they are all printed 3-to-a-
page. Follow the 3-to-a-page measurements in Section 6. Form 1098-C can be found at IRS.gov/
Form1098C. Print the form to actual size with no scaling.
2.1.2
General Requir
ements
Form identifying numbers (for example, 9191 for Form 1099-DIV) must be printed in nonreflective
black carbon-based ink in print positions 15 through 19 using an optical character recognition
(OCR) A font. The checkboxes to the right of the form identifying numbers must be 10-point
boxes. The “VOID” checkbox is in print position 25 (1.9 inches from left vertical line of the form).
The “CORRECTED” checkbox is in print position 33 (2.7 inches from left vertical line of the
form). Measurements are generally from the left edge of the paper, not including the perforated
strip.

Bulletin No. 2024–30 131 July 22, 2024
The substitute form Copy A must be an exact replica of the official IRS form with respect to layout
and content. To determine the correct form measurements, see Exhibits A through CC at the end
of this publication.
Hot wax and cold carbon spots are not permitted on any of the internal form plies. These spots are
permitted on the back of a mailer top envelope ply.
Use of chemical transfer paper for Copy A is acceptable.
The Government Publishing Office (GPO) symbol must be deleted.
2.1.3
Color
and Paper Quality
Color and paper quality for Copy A (cut sheets and continuous pinfeed forms) as specified by JCP
Code 0-25, dated November 29, 1978, must be white 100% bleached chemical wood, OCR bond
produced in accordance with the following specifications.
Note. Reclaimed fiber in any percentage is permitted, provided the requirements of this standard
are met.
Acidity: Ph value, average, not less than4.5
Basis Weight: 17 x 22-500 cut sheets18-20
Metric equivalent–g/m275
A tolerance of ±5 pct. is allowed.
Stiffness: Average, each direction, not less than-milligrams50
Tearing strength: Average, each direction, not less than-grams40
Opacity: Average, not less than-percent82
Thickness: Average-inch0.0038
Metric equivalent-mm0.097
A tolerance of +0.0005 inch (0.0127 mm) is allowed. Paper cannot
vary more than 0.0004 inch (0.0102 mm) from one edge to the other.
Porosity: Average, not less than-seconds10
Finish (smoothness): Average, each side-seconds20-55
For information only, the Sheffield equivalent-units170-100
Dirt: Average, each side, not to exceed-parts per million8
2.1.4
Chemical T
ransfer Paper
Chemical transfer paper is permitted for Copy A only if the following standards are met.
• Only chemically backed paper is acceptable for Copy A. Front and back chemically treated
paper cannot be processed properly by machine.
• Carbon-coated forms are not permitted.
• Chemically transferred images must be black.
All copies must be clearly legible. Fading must be minimized to assure legibility.

July 22, 2024 132 Bulletin No. 2024–30
2.1.5
Printing
All print on Copy A of Forms 1097-BTC, 1098, 1098-C, 1098-E, 1098-F, 1098-MA, 1098-Q,
1098-T, 1099-A, 1099-B, 1099-C, 1099-DIV, 1099-G, 1099-INT, 1099-K, 1099-LS, 1099-MISC,
1099-NEC, 1099-OID, 1099-PATR, 1099-Q, 1099-R, 1099-S, 1099-SB, 3921, 3922, and 5498;
and the print on Form 1096 above the statement, “Return this entire page to the Internal Revenue
Service. Photocopies are not acceptable.” must be in Flint J-6983 red OCR dropout ink or an exact
match. However, the 4-digit form identifying number must be in nonreflective carbon-based black
ink in OCR A font.
The shaded areas of any substitute form should generally correspond to the format of the official
form.
The printing for the Form 1096 jurat statement and the text that follows may be in any shade or
tone of black ink. Black ink should only appear on the lower part of the reverse side of Form 1096,
where it will not bleed through and interfere with scanning.
Note. The instructions on the front and back of Form 1096, which include filing addresses, must
be printed.
Separation between fields must be 0.1 inch.
Other printing requirements are discussed in Sections 2.1.6 through 2.1.10.
2.1.6
OCR Specifications
You must initiate, or have, a quality control program to assure OCR ink density. Readings will be
made when printed on approved 20 lb. white OCR bond with a reflectance of not less than 80%
(0.80). Black ink must not have a reflectance greater than 15% (0.15). These readings are based
on requirements of the “BancTec IntelliScan XDS” Optical Scanner using Flint J-6983 red OCR
dropout ink or an exact match.
The following testers and ranges are acceptable.
Important information: The forms produced under these specifications must be guaranteed to
function properly when processed through High Speed Scan-Optics 9000 mm scanners. Forms
require precision spacing, printing, and trimming.
Density readings on the solid Flint J-6983 (red) must be between the ranges of 0.95 to 0.90. The
optimal scanning range is 0.93. Density readings on the solid black must be between the ranges of
112 to 108. The optimal scanning range is 110.
Note. The readings are taken using an Ex-Rite 500 series densitometer, in Status T with Absolute
or – paper setting under an Illuminate 5000 Kelvin Watt Light. You must maintain print contrast
specification of ink and densitometer reflectivity reading throughout the entire production run.
• MacBeth PCM-II. The tested Print Contrast Signal (PCS) values when using the MacBeth
PCM-II tester on the “C” scale must range from 0.01 minimum to 0.06 maximum.

Bulletin No. 2024–30 133 July 22, 2024
• Kidder 082A. The tested PCS values when using the Kidder 082A tester on the Infra Red
(IR) scale must range from 0.12 minimum to 0.21 maximum. White calibration disc must be
100%. Sensitivity must be set at one (1).
• Alternative testers must be approved by the IRS to establish tested PCS values. You may
obtain approval by writing to the following address.
Internal Revenue Service
Attn: Substitute Forms Program
C:DC:TS:CAR:MP:P:TP:TP
ATSC
4800 Buford Highway
Mail Stop 061-N
Chamblee, GA 30341
2.1.7
T
ypography
Type must be substantially identical in size and shape to the official form. All rules are either
1
/2-
point or
3
/4-point. Rules must be identical to those on the official IRS form.
Note. The form identifying number must be nonreflective carbon-based black ink in OCR A font.
2.1.8
Dimensions
Generally, three Copies A of Forms 1098, 1099, 3921, and 3922 are contained on a single page
(3-to-a-page), 8 inches wide (without any snap-stubs and/or pinfeed holes) by 11 inches deep.
Exceptions. Forms 1097-BTC, 1098, 1098-Q, 1099-B, 1099-DIV, 1099-INT, 1099-K, 1099-
MISC, 1099-OID, 1099-R, and 5498 contain two copies on a single page (2-to-a-page). Forms
1098-C and 1042-S are single-page documents.
There is a 0.33-inch top margin from the top of the corrected box, and a 0.2- to 0.25-inch right
margin, with a +/-
1
/20 (0.05) inch tolerance for the right margin. If the right and top margins are
properly aligned, the left margin for all forms will be correct. All margins must be free of print.
See Exhibits A through CC in Part 6 for correct form measurements.
These measurements are constant for certain Forms 1098, 1099, and 5498. These measurements
are shown only once in this publication, on Form 1097-BTC (Exhibit B) 2-to-a-page and on Form
1098-E (Exhibit E) 3-to-a-page.
Exceptions to these measurements, and form-specific measurements are shown on the rest of the
exhibits.
The depth of the individual trim size of each 3-to-a-page form must be 3
2
/3 inches, the same depth
as the official form, unless otherwise indicated.
The depth of the individual trim size of each 2-to-a-page form is 5
1
/2 inches.

July 22, 2024 134 Bulletin No. 2024–30
2.1.9
Perforation
Copy A (3-to-a-page and 2-to-a-page) of privately printed continuous substitute forms must be
perforated at each 11 inches page depth. No perforations are allowed between forms on the Copy
A page.
Exception. Copy A of Form W-2G may be perforated.
The words “Do Not Cut or Separate Forms on This Page” must be printed using Flint J-6983 red
OCR dropout ink or an exact match (see Section 2.1.5) between the 3-to-a-page or 2-to-a-page.
This statement should not be included after the last form on the page.
Separations are required between all the other individual copies (Copy B, and Copies 1 and 2 of
Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-K, 1099-MISC, 1099-NEC, and 1099-OID;
and Copy C of Form 1099-R; and Copy D of Forms 1099-LS, 1099-LTC, 1099-R, and 1042-S) in
the set. Any recipient copies printed on a single sheet of paper must be easily separated. The best
method of separation is to provide perforations between the individual copies. Each copy should
be easily distinguished, whatever method of separation is used.
Note. Perforation does not apply to printouts of copies that are furnished electronically to recipients
(as described in Regulations section 31.6051-1(j)). However, these recipients should be cautioned
to carefully separate any copies. See Section 4.6.1 for information on electronically furnishing
statements to recipients.
2.1.10
Required Inclusions/
Exclusions
You must include the Office of Management and Budget (OMB) number on Copies A and Form
1096 in the same location as on the official form.
The following Privacy Act and Paperwork Reduction Act Notice phrases must be printed on Copy
A of the forms as follows. It must also be printed on the Copy C or D of the form retained by the
filer, if applicable.
• “For Privacy Act and Paperwork Reduction Act Notice, see the current version of the General
Instructions for Certain Information Returns” on Forms 3921 and 3922.
• “For more information and the Privacy Act and Paperwork Reduction Act Notice, see
the 2024 General Instructions for Certain Information Returns” on Form 1096.
• “For Privacy Act and Paperwork Reduction Act Notice, see instructions” on Form 1042-
S.
• “For Privacy Act and Paperwork Reduction Act Notice, see the 2024 General Instructions
for Certain Information Returns” must be printed on all other forms listed in Section
1.1.2.
A postal indicia may be used if it meets the following criteria.
• It is printed in the OCR ink color prescribed for the form.
• No part of the indicia is within one print position of the scannable area.
The printer’s symbol (GPO) must not be printed on substitute Copy A. Instead, the EIN or the
vendor code of the form’s printer must be entered in place of the Catalog Number (Cat. No.). The
4-digit vendor code, preceded by four zeros and a slash, for example, 0000/9876, must appear in

Bulletin No. 2024–30 135 July 22, 2024
12-point Arial font, or a close approximation, on Copy A only of Forms 1096, 1097-BTC, 1098,
1099, 3921, 3922, 5498, and W-2G. The vendor code is used to identify the forms producer.
Vendor codes can be obtained free of charge from the National Association of Computerized Tax
Processors (NACTP) via email at president@nactp.org. The use of a vendor code is recommended.
Note. Vendor codes from the NACTP are required by those companies producing the 1099 family
of forms (Forms 1096, 1097-BTC, 1098, 1099, 3921, 3922, 5498, and W-2G) as part of a product
for resale to be used by multiple issuers. Issuers developing 1099 family forms to be used only for
their individual companies do not require a vendor code.
The Cat. No. shown on the forms is used for IRS distribution purposes and should not be printed
on any substitute forms.
The form must not contain the statement “IRS approved” or any similar statement.
Section 2.2 – Instructions for Preparing Paper Forms That Will Be Filed With the IRS
2.2.1
Recipient Information
The form recipient’s name, street address, city, state, ZIP code, and telephone number (if required)
should be typed or machine printed in black ink in the same format as shown on the official IRS
form. The city, state, and ZIP code must be on the same line.
The following rules apply to the form recipient’s name(s).
• The name of the appropriate form recipient must be shown on the first or second name line in
the area provided for the form recipient’s name.
• No descriptive information or other name may precede the form recipient’s name.
• Only one form recipient’s name may appear on the first name line of the form.
• If multiple recipients’ names are required on the form, enter on the first name line the recip-
ient name that corresponds to the recipient TIN shown on the form. Place the other form
recipients’ names on the second name line (only 2 name lines are allowable).
Because certain states require that trust accounts be provided in a different format, filers should
generally provide information returns reflecting payments to trust accounts with the:
• Trust’s EIN in the recipient’s TIN area,
• Trust’s name on the recipient’s first name line, and
• Name of the trustee on the recipient’s second name line.
Although handwritten forms will be accepted, the IRS prefers that filers type or machine print
data entries. Also, filers should insert data as directed by shading, or in the middle of blocks, well
separated from other printing and guidelines, and take measures to guarantee clear, dark black,
sharp images. Photocopies are not acceptable.
Truncating payee TIN on payee statements. Where permitted, filers may truncate a payee’s
TIN (social security number (SSN), individual taxpayer identification number (ITIN), adoption

July 22, 2024 136 Bulletin No. 2024–30
taxpayer identification number (ATIN), or EIN) on the payee statement (including substitute and
composite substitute statements) furnished to the payee in paper form or electronically. Generally,
the payee statement is that copy of an information return designated “Copy B” on the form. To
truncate where allowed, replace the first 5 digits of the 9-digit number with asterisks (*) or Xs
(for example, an SSN xxx-xx-xxxx would appear on the paper payee statement as ***-**-xxxx
or XXX-XX-xxxx). See Treasury Decision 9675, 2014-31 I.R.B. 242, available at IRS.gov/irb/
2014-31_IRB#TD-9675.
Caution. Recipient TINs must not be truncated on Copy A filed with the IRS.
2.2.2
Account Number
Box
Use the account number box on all Forms 1098, 1099, 3921, 3922, 5498, and W-2G for an account
number designation when required by the official IRS form. The account number is required if you
have multiple accounts for a recipient for whom you are filing more than one information return
of the same type. Additionally, the IRS encourages you to include the recipients’ account numbers
on paper forms if your system of records uses the account number rather than the name or TIN
for identification purposes. Also, the IRS will include the account number in future notices to you
about backup withholding. If you are using window envelopes to mail statements to recipients and
using reduced rate mail, be sure the account number does not appear in the window. The Postal
Service may not accept these for reduced rate mail.
Exception. Form 1098-T can have third-party provider information.
2.2.3
Specifications and
Restrictions
• Machine-printed forms should be printed using a 6 lines/inch option, and should be printed
in 10 pitch pica (10 print positions per inch) or 12 pitch elite (12 print positions per inch).
Proportional spaced fonts are unacceptable.
• Substitute forms prepared in continuous or strip form must be burst and stripped to conform
to the size specified for a single sheet before they are filed with the IRS. The size specified
does not include pinfeed holes. Pinfeed holes must not be present on forms filed with the
IRS.
• Do not use a felt tip marker. The machine used to “read” paper forms generally cannot read
this ink type.
• Do not use dollar signs ($), ampersands (&), asterisks (*), commas (,), or other special char-
acters in the numbered money boxes. Exception. Use decimal points to indicate dollars and
cents (for example, 2000.00 is acceptable).
• Do not use apostrophes (’), asterisks (*), or other special characters on the payee name line.
• Do not fold Forms 1097-BTC, 1098, 1099, 3921, 3922, or 5498 mailed to the IRS. Mail these
forms flat in an appropriately sized envelope or box. Folded documents cannot be readily
moved through the machine used in IRS processing.
• Do not staple Forms 1096 to the transmitted returns. Any staple holes near the return code
number may impair the IRS’s ability to machine scan these types of documents.
• Do not type other information on Copy A.
• Do not cut or separate the individual forms on the sheet of forms of Copy A (except Forms
W-2G).

Bulletin No. 2024–30 137 July 22, 2024
Mail completed paper forms to the IRS Service Center shown in the instructions for Form 1096
and in the 2024 General Instructions for Certain Information Returns. Specific information
needed to complete the forms mentioned in this revenue procedure are given in the specific form
instructions. A chart showing which form must be filed to report a particular payment is included
in the 2024 General Instructions for Certain Information Returns.
Part 3
Specifications for Substitute Form W-2G (Filed With the IRS)
2.2.4
Wher
e To File
Section 3.1 – General
3.1.1
Purpose
The following specifications give the format requirements for substitute Form W-2G (Copy A
only), which is filed with the IRS.
A filer may use a substitute Form W-2G to file with the IRS (referred to as “substitute Copy A”).
The substitute form must be an exact replica of the official form with respect to layout and content.
Section 3.2 – Specifications for Copy A of Form W-2G
3.2.1
Substitute Form W-2G
(Copy A)
You must follow these specifications when printing substitute Copy A of the Form W-2G.
Caution. The payee’s TIN (SSN, ITIN, ATIN, or EIN) must not be truncated on Copy A of Form
W2-G.
ItemSubstitute Form W-2G (Copy A)
Paper Color and
Quality
Paper for Copy A must be white chemical wood bond, or equivalent, 20
pounds (basis 17 x 22-500), plus or minus 5% (0.05). The paper must
consist substantially of bleached chemical wood pulp. It must be free from
unbleached or ground wood pulp or post-consumer recycled paper. It must
also be suitably sized to accept ink without feathering.
Ink Color and
Quality
All printing must be in a high quality nongloss black ink.
TypographyThe type must be substantially identical in size and shape to the official
form. All rules on the document are either
1
/2 point (0.007 inch), 1 point
(0.015 inch), or 3 point (0.045 inch). Vertical rules must be parallel to the
left edge of the document; horizontal rules to the top edge.

July 22, 2024 138 Bulletin No. 2024–30
ItemSubstitute Form W-2G (Copy A)
DimensionsThe official form is 8 inches wide x 5
1
/2 inches deep, exclusive of a snap
stub. Any substitute Copy A can be between 8 inches and 8
1
/2 inches
wide by 5 inches deep. The snap feature is not required on substitutes. All
margins must be free of print. There is a 0.33-inch top margin from the
top of the corrected box, and a
1
/2-inch left margin. If the top and left
margins are properly aligned, the right margin for all forms will be correct.
If the substitute forms are in continuous or strip form, they must be burst
and stripped to conform to the size specified for a single form.
Hot Wax and
Cold Carbon
Spots
Hot wax and cold carbon spots are not permitted on any of the internal
form plies. These spots are permitted on the back of a mailer top envelope
ply.
Printer’s SymbolThe GPO symbol must not be printed on substitute Forms W-2G. Instead,
the EIN of the form’s printer must be printed in the bottom margin on the
face of each individual Copy A on a sheet. The form must not contain the
statement “IRS approved” or any similar statement.
Cat. No.The Cat. No. shown on Form W-2G is used for IRS distribution purposes
and should not be printed on any substitute forms.
Part 4
Substitute Statements to Form Recipients and Form Recipient Copies
Section 4.1 – Specifications
4.1.1
Intr
oduction
If you do not use the official IRS form to furnish statements to recipients, you must furnish an
acceptable substitute statement. Information presented in substitute statements should be in a point
size large enough to be easily read by recipients. To be acceptable, your substitute statement must
comply with the rules in this part. If you are furnishing a substitute form, see Regulations sections
1.6042-4, 1.6044-5, 1.6049-6, and 1.6050N-1 to determine how the following statements must be
provided to recipients for most Forms 1099-DIV and 1099-INT, all Forms 1099-OID and 1099-
PATR, and Form 1099-MISC, or Form 1099-S for royalties. Generally, information returns may be
furnished electronically with the consent of the recipient. See Section 4.6.1.
Note. A trustee of a grantor-type trust may choose to file Forms 1099 and furnish a statement to
the grantor under Regulations sections 1.671-4(b)(2)(iii) and (b)(3)(ii). The statement required by
those regulations is not subject to the requirements outlined in this section.
4.1.2
Substitute Statements to
Recipients for Certain
Forms 1099-B, 1099- DIV,
1099-INT, 1099-OID, and
1099-PATR
The rules in this section apply to Form 1099-B, 1099-DIV (except for section 404(k) dividends),
1099-INT (except for interest reportable under section 6041), 1099-OID, and 1099-PATR only.
You may furnish form recipients with Copy B of the official Form 1099 or a substitute Form 1099
(recipient statement) if it contains the same information as the official IRS form (such as aggregate
amounts paid to the form recipient; any backup withholding; the name, address, and TIN of the
person making the return; and any other information required by the official form). Information not
required by the official form should not be included on the substitute form except for state income
tax withholding information. But see Section 4.3 regarding additional information that may be
included on substitute and composite Forms 1099-B, such as basis for noncovered securities.

Bulletin No. 2024–30 139 July 22, 2024
Note. Many of the information returns now include boxes for providing state withholding
information as part of the official form, with additional copies for convenience. Payers may,
however, provide the state withholding information separately (such as on a separate page or
section) in order to assist the payee with completing a state income tax return that requires the
attachment of any information return that includes state withholding amounts and payer numbers.
Exception for supplementary information. The substitute form may include supplementary
information that will assist the payee with completing the tax return. Such information could
include expense and cost basis factors related to the reporting for widely held fixed investment
trusts (WHFITs), as required under Regulations section 1.671-5. The substitute statement should
disclose to the payee that such supplementary information is not furnished to the IRS. See Section
4.3 for additional requirements when providing supplemental information with the Form 1099-B
that is not furnished to the IRS.
Form 1099-B. For transactions reportable on Form 8949, brokers that use substitute statements
should segregate dispositions of noncovered securities from covered securities, and further
segregate long-term and short-term dispositions of covered securities. They may also segregate
long-term from short-term dispositions of noncovered securities, to the extent that the date
acquired is known. For 2024 dispositions, the substitute Forms 1099-B may have up to five
separate sections, each with a heading identifying which securities are included in the list, and
each separately totaled. Each section, after totaling or within the heading for the section, should
indicate how to report the transactions on Form 8949, as indicated.
1. Short-term transactions for which basis is reported to the IRS—Report on Form 8949, Part
I, with Box A checked.
2. Short-term transactions for which basis is not reported to the IRS—Report on Form 8949,
Part I, with Box B checked.
3. Long-term transactions for which basis is reported to the IRS—Report on Form 8949, Part
II, with Box D checked.
4. Long-term transactions for which basis is not reported to the IRS—Report on Form 8949,
Part II, with Box E checked.
5. Transactions for which basis is not reported to the IRS and for which short-term or long-term
determination is unknown (to Broker). You must determine short term or long term based on
your records and report on Form 8949, Part I, with Box B checked, or on Form 8949, Part
II, with Box E checked, as appropriate.
For each section, each transaction may include information not reported to the IRS, such as basis,
date acquired, and gain or loss. Therefore, for short-term dispositions where basis was not reported
to the IRS, basis and date acquired may be shown just as they would be shown for short-term
dispositions where basis was reported to the IRS.
For 2024 dispositions, each of the applicable sections must have Sales Price and Cost or Other
Basis (if known) separately totaled. Net gain or loss, if included for any of the sections, may also
be totaled.
Brokers may also use substitute Form 1099-B for transactions that are not directly reported on
Form 8949. Examples include transactions involving regulated futures contracts, foreign currency
contracts, and section 1256 option contracts. Any additional sections created for this purpose
should be segregated from those transactions directly reportable on Form 8949.

July 22, 2024 140 Bulletin No. 2024–30
The substitute form requirements in the following paragraphs also apply to Form 1099-B.
Form 1099-INT, 1099-DIV, 1099-OID, or 1099-PATR. A substitute recipient statement for Form
1099-INT, 1099-DIV, 1099-OID, or 1099-PATR must comply with the following requirements.
• Box captions and numbers that are applicable must be clearly identified, using the same
wording and numbering as on the official form.
• The recipient statement (Copy B) must contain all applicable recipient instructions as pro-
vided on the front and back of the official IRS form. You may provide those instructions on
a separate sheet of paper.
• The box caption “Federal income tax withheld” must be in boldface type or otherwise
highlighted on the recipient statement.
• The recipient statement must contain the OMB number as shown on the official IRS form.
See Section 5.2.
• The recipient statement must contain the tax year (for example, 2024), form number (for
example, Form 1099-INT), and form name (for example, Interest Income) of the official
IRS Form 1099. This information must be displayed prominently together in one area of the
statement. For example, the tax year, form number, and form name could be shown in the
upper right part of the statement. Each copy must be appropriately labeled (such as Copy
B, For Recipient). See Section 4.5.2 for applicable labels and arrangement of assembly of
forms. Note. Do not include the words “Substitute for” or “In lieu of” on the recipient state-
ment.
• Layout and format of the statement are at the discretion of the filer. However, the IRS encour-
ages the use of boxes so that the statement has the appearance of a form and can be easily
distinguished from other nontax statements.
• Each recipient statement of Form 1099-B, 1099-DIV, 1099-INT, 1099-OID, or 1099-PATR
must include the direct access telephone number of an individual who can answer questions
about the statement. Include that telephone number conspicuously anywhere on the recipi-
ent statement.
A mutual fund family may furnish one statement (for example, one piece of paper) on which
it reports the dividend income earned by a recipient from multiple funds within the family of
mutual funds, as required by Form 1099-DIV. However, each fund and its earnings must be stated
separately. The statement must contain an instruction to the recipient that each fund’s dividends
and name, not the name of the mutual fund family, must be reported on the recipient’s tax
return. The statement cannot contain an aggregate total of all funds. In addition, a mutual fund
family may furnish a single statement (as a single filer) for Form 1099-INT, 1099-DIV, or 1099-
OID information (see Section 4.2.1). Each fund and its earnings must be stated separately. The
statement must contain an instruction to the recipient that each fund’s earnings and name, not
the name of the mutual fund family, must be reported on the recipient’s tax return. The statement
cannot contain an aggregate total of all funds.
You may enter a total of the individual accounts listed on the statement only if they have been paid
by the same payer. For example, if you are listing interest paid on several accounts by one financial
institution on Form 1099-INT, you may also enter the total interest amount. You may also enter a
date next to the CORRECTED box if that box is checked.

Bulletin No. 2024–30 141 July 22, 2024
4.1.3
Substitute Statements to
Recipients for Certain
Forms 1098, 1099, 5498,
and W-2G
Statements to form recipients for Forms 1097-BTC, 1098, 1098-C, 1098-E, 1098-F, 1098-MA,
1098-Q, 1098-T, 1099-A, 1099-C, 1099-CAP, 1099-G, 1099-K, 1099-LS, 1099-LTC, 1099-
MISC, 1099-NEC, 1099-Q, 1099-QA, 1099-R, 1099-S, 1099-SA, 1099-SB, 3921, 3922, 5498,
5498-ESA, 5498-QA, 5498-SA, W-2G, 1099-DIV (only for section 404(k) dividends reportable
under section 6047), and 1099-INT (only for interest of $600 or more made in the course of a
trade or business reportable under section 6041) can be copies of the official forms or acceptable
substitutes.
Caution. The IRS does not require a donee to use Form 1098-C as the written acknowledgment
for contributions of motor vehicles, boats, and airplanes. However, if you choose to use copies of
Form 1098-C or an acceptable substitute as the written acknowledgment, then you must follow
the requirements of this section.
To be acceptable, a substitute recipient statement must meet the following requirements.
• The tax year, form number, and form name must be the same as on the official form and must
be displayed prominently together in one area on the statement. For example, they may be
shown in the upper right part of the statement.
• The statement must contain the same information as the official IRS form, such as aggregate
amounts paid to the form recipient; any backup withholding; the name, address, and TIN of
the filer and of the recipient; and any other information required by the official form.
• Each substitute recipient statement for Forms W-2G, 1097-BTC, 1098, 1098-C, 1098-E,
1098-F, 1098-T, 1099-A, 1099-C, 1099-CAP, 1099-DIV, 1099-G (excluding state and local
income tax refunds), 1099-K, 1099-INT, 1099-LS, 1099-LTC, 1099-MISC (excluding fish-
ing boat proceeds), 1099-NEC, 1099-Q, 1099-R (for qualified long-term care insurance con-
tracts under combined arrangements only), 1099-S, 1099-SA, 1099-SB, and 5498-SA must
include the direct access telephone number of an individual who can answer questions about
the statement.
• Include the telephone number conspicuously anywhere on the recipient statement. Although
not required, payers reporting on Forms 1099-QA, 1099-R (payments other than qualified
long-term care insurance contracts under combined arrangements), 3921, 3922, 5498, 5498-
ESA, and 5498-QA are encouraged to furnish telephone numbers at which recipients of the
form(s) can reach a person familiar with the information reported.
• All applicable money amounts and information, including box numbers required to be
reported to the form recipient, must be titled on the recipient statement in substantially the
same manner as those on the official IRS form. The box caption “Federal income tax with-
held” must be in boldface type on the recipient statement.
Exception. If you are reporting a payment as “Other income” in box 3 of Form 1099-MISC,
you may substitute appropriate language for the box title. For example, for payments of
accrued wages and leave to a beneficiary of a deceased employee, you might change the title
of box 3 to “Beneficiary payments” or something similar.
Note. You cannot make this change on Copy A.
• If federal income tax is withheld and shown on Form 1099-R or W-2G, Copy B and Copy
C must be furnished to the recipient. If federal income tax is not withheld, only Copy C of
Forms 1099-R and W-2G must be furnished. However, for Form 1099-R, instructions simi-
lar to those on the back of the official Copy B and Copy C of Form 1099-R must be furnished
to the recipient. For convenience, you may choose to provide both Copies B and C of Form
1099-R to the recipient.

July 22, 2024 142 Bulletin No. 2024–30
• You must provide appropriate instructions to the form recipient similar to those on the offi-
cial IRS form, to aid in the proper reporting on the form recipient’s income tax return. For
payments reported on Forms 1099-B and 1099-CAP, the requirement to include instructions
substantially similar to those on the official IRS form may be satisfied by providing form
recipients with a single set of instructions for all Forms 1099-B and 1099-CAP statements
required to be furnished in a calendar year.
• If you use carbonless sets to produce recipient statements, the quality of each copy in the set
must meet the following standards.
1. All copies must be clearly legible.
2. All copies must be able to be photocopied.
3. Fading must not diminish legibility and the ability to photocopy.
• In general, black chemical transfer inks are preferred, but other colors are permitted if the
above standards are met. Hot wax and cold carbon spots are not permitted on any of the
internal form plies. The back of a mailer top envelope ply may contain these spots.
• For reporting state income tax withholding and state payments, you may add an additional
box(es) to recipient copies, as appropriate. In addition, the state withholding information
may be provided separately and apart from the other information in the event the recipient
must attach a copy to the recipient’s tax return. Note. You cannot make this change on Copy
A.
• On Copy C of Form 1099-LTC, you may reverse the location of the policyholder’s and the
insured’s name, street address, city, state, and ZIP code for easier mailing.
• If an institution insurer uses a third-party service provider to file Form 1098-T, then in addi-
tion to the institution’s or insurer’s name, address, and telephone number, the same informa-
tion may be included for the third-party service provider in the space provided on the form.
• Forms 1099-A and 1099-C transactions, if related, may be combined on Form 1099-C.
4.1.4
Online Fillable Copies B, C,
D, 1, and 2
Copies B, C, D, 1, and 2, as applicable, to be furnished to recipients and kept in the filers’ records,
have been made online fillable at IRS.gov/forms-instructions for many forms referenced in these
instructions. See the separate instructions for Forms 1098, 1098-E & T, 1098-F, 1098-Q, 1099-A
& C, 1099-B, 1099-DIV, 1099-G, 1099-INT & OID, 1099-K, 1099-LS, 1099-MISC & NEC,
1099-PATR, 1099-R & 5498, 1099-S, 1099-SB, and 3921.
Section 4.2 – Composite Statements
4.2.1
Composite Substitute
Statements for
Certain
Forms 1099-B, 1099- DIV,
1099-INT, 1099-MISC,
1099-OID, 1099-PATR,
and 1099- S
A composite recipient statement is permitted for reportable payments consisting of the proceeds of
brokerage and barter transactions, dividends, interest, original issue discount, patronage dividends,
and royalties. The following forms may be included on a composite substitute statement, when
one payer is reporting more than one of these payments during a calendar year to the same form
recipient.
• Form 1099-B.
• Form 1099-DIV (except for section 404(k) dividends).

Bulletin No. 2024–30 143 July 22, 2024
• Form 1099-INT (except for interest reportable under section 6041).
• Form 1099-MISC (only for royalties or substitute payments in lieu of dividends and interest).
• Form 1099-OID.
• Form 1099-PATR.
• Form 1099-S (only for royalties).
Generally, do not include any other Form 1099 information (for example, Form 1099-A or 1099-
C) on a composite statement with the information required on the forms listed in the preceding
sentence.
Although the composite recipient statement may be on one sheet, the format of the composite
recipient statement must satisfy the following requirements in addition to the requirements listed
in Sections 4.1.2, 4.3, and 4.4, as applicable.
• All information pertaining to a particular type of payment must be located and blocked
together on the form and separate from any information covering other types of payments
included on the form. For example, if you are reporting interest and dividends, the Form
1099-INT information must be presented separately from the Form 1099-DIV information.
• The composite recipient statement must prominently display the form number and form
name of the official IRS form together in one area at the beginning of each appropriate block
of information. The tax year must only be placed on each block of information if it is not
prominently displayed elsewhere on the page on which the information appears.
• Any information required by the official IRS forms that would otherwise be repeated in each
information block is required to be listed only once in the first information block on the
composite form. For example, there is no requirement to report the name of the filer in each
information block. This rule does not apply to any money amounts (for example, federal
income tax withheld) or to any other information that applies to money amounts.
• A composite statement is an acceptable substitute only if the type of payment, and the recipi-
ent’s tax obligation with respect to the payment, is as clear as if each required statement were
furnished separately on an official form.
4.2.2
Composite Substitute
Statements to Recipients
for
Forms Specified in Sections
4.1.2 and 4.1.3
A composite recipient statement for the forms specified in Section 4.1.2 or 4.1.3 is permitted when
one filer is reporting more than one type of payment during a calendar year to the same form
recipient. A composite statement is not allowed for a combination of forms listed in Sections 4.1.2
and 4.1.3.
Exceptions.
• Substitute payments in lieu of dividends or interest reported in box 8 of Form 1099-MISC
may be reported on a composite substitute statement with Form 1099-DIV.
• Form 1099-B information may be reported on a composite form with the forms specified in
Section 4.1.2, as described in Section 4.2.1.
• Royalties reported on Form 1099-MISC or 1099-S may be reported on a composite form only
with the forms specified in Section 4.1.2.

July 22, 2024 144 Bulletin No. 2024–30
Although the composite recipient statement may be on one sheet, the format of the composite
recipient statement must satisfy the requirements listed in Section 4.2.1 as well as the requirements
in Section 4.1.3. A composite statement of Forms 1098 and 1099-INT (for interest reportable
under section 6049) is not allowed.
Section 4.3 – Additional Information for Substitute and Composite Forms 1099-B
4.3.1
General Requir
ements for
Presenting Additional Form
1099-B Information
A filer may include Form 1099-B information on a composite form with the forms listed in
Section 4.1.2. Therefore, supporting, explanatory, or comparable relevant information for covered
and noncovered lots on the 1099-B portion of the composite statement can be included. This
information includes display on the payee statement of data elements such as basis for noncovered
lots, explanatory remarks on permissible basis adjustments for covered lots, descriptions of the
type of transaction (merger, buy to close, redemption, etc.), identification of contingent payment
debt obligations, and lot relief methods.
If you wish to provide additional information to the investor on the same substitute recipient
Form 1099-B, the form must follow the rules set forth in this Section 4.3 and should clearly
delineate how the information is presented. Any information presented should make reference to
its corresponding number on the official form, as appropriate. You should clearly categorize each
type of information you are reporting.
4.3.2
Added Legend for
Providing Additional Form
1099-B Information
An additional separate legend is required that explains exactly which pieces of information are
and are not reported to the IRS, to the extent, if any, the information is not already identified as
not being reported to the IRS, as described in Section 4.1.2. It should clearly explain how the
information is presented. You may present this legend in a way that is consistent with your design
as long as it clearly indicates which information is being provided to the IRS. Additionally, a
reminder to taxpayers that they are ultimately responsible for the accuracy of their tax returns is
also required.
Section 4.4 – Required Legends
4.4.1
Required Legends for
Forms 1098
Form 1098 recipient statements (Copy B) must contain the following legends.
• Form 1098:
1. “The information in boxes 1 through 9 and 11 is important tax information and is being
furnished to the IRS. If you are required to file a return, a negligence penalty or other
sanction may be imposed on you if the IRS determines that an underpayment of tax
results because you overstated a deduction for the mortgage interest or for these points,
reported in boxes 1 and 6; or because you did not report the refund of interest (box 4);
or because you claimed a nondeductible item.”
2. “Caution. The amount shown may not be fully deductible by you. Limits based on the
loan amount and the cost and value of the secured property may apply. Also, you may
only deduct interest to the extent it was incurred by you, actually paid by you, and not
reimbursed by another person.”

Bulletin No. 2024–30 145 July 22, 2024
• Form 1098-C: Copy B — “In order to take a deduction of more than $500 for this contribu-
tion, you must attach this copy to your federal tax return. Unless box 5a or 5b is checked,
your deduction cannot exceed the amount in box 4c.” Copy C — “This information is
being furnished to the IRS unless box 7 is checked.”
• Form 1098-E: “This is important tax information and is being furnished to the IRS. If you are
required to file a return, a negligence penalty or other sanction may be imposed on you if the
IRS determines that an underpayment of tax results because you overstated a deduction for
student loan interest.”
• Forms 1098-F and 1098-MA: “This is important tax information and is being furnished to the
IRS.”
• Form 1098-Q: “This information is being furnished to the IRS.”
• Form 1098-T: “This is important tax information and is being furnished to the IRS. This form
must be used to complete Form 8863 to claim education credits. Give it to the tax preparer
or use it to prepare the tax return.”
4.4.2
Requir
ed Legends for
Forms 1099 and W-2G
• Forms 1099-A, 1099-C, 1099-CAP, and 1099-K: Copy B — “This is important tax informa-
tion and is being furnished to the IRS. If you are required to file a return, a negligence penalty
or other sanction may be imposed on you if taxable income results from this transaction and
the IRS determines that it has not been reported.”
• Forms 1099-B, 1099-DIV, 1099-G, 1099-INT, 1099-MISC, 1099-NEC, 1099-OID, 1099-
PATR, 1099-Q, and 1099-QA: Copy B — “This is important tax information and is being
furnished to the IRS. If you are required to file a return, a negligence penalty or other sanc-
tion may be imposed on you if this income is taxable and the IRS determines that it has not
been reported.”
• Form 1099-LS: Copy B — “This is important tax information and is being furnished to
the IRS. If you are required to file a return, a negligence penalty or other sanction may be
imposed on you if this item is required to be reported and the IRS determines that it has not
been reported.” Copy C — “Copy C is provided to you for information only. Only the pay-
ment recipient is required to report this information on a tax return.”
• Form 1099-LTC: Copy B — “This is important tax information and is being furnished to
the IRS. If you are required to file a return, a negligence penalty or other sanction may be
imposed on you if this item is required to be reported and the IRS determines that it has not
been reported.” Copy C — “Copy C is provided to you for information only. Only the poli-
cyholder is required to report this information on a tax return.”
• Form 1099-R: Copy B — “Report this income on your federal tax return. If this form
shows federal income tax withheld in box 4, attach this copy to your return.” Copy C —
“This information is being furnished to the IRS.”
• Forms 1099-S and 1099-SB: Copy B — “This is important tax information and is being fur-
nished to the IRS. If you are required to file a return, a negligence penalty or other sanction
may be imposed on you if this item is required to be reported and the IRS determines that it
has not been reported.”
• Form 1099-SA: Copy B — “This information is being furnished to the IRS.”
• Form W-2G: Copy B — “This information is being furnished to the IRS. Report this income
on your federal tax return. If this form shows federal income tax withheld in box 4,
attach this copy to your return.” Copy C — “This is important tax information and is

July 22, 2024 146 Bulletin No. 2024–30
being furnished to the IRS. If you are required to file a return, a negligence penalty or other
sanction may be imposed on you if this income is taxable and the IRS determines that it has
not been reported.”
4.4.3
Requir
ed Legends for
Forms 1097-BTC, 3921,
3922, and 5498
• Form 1097-BTC: Copy B — “This is important tax information and is being furnished to
the IRS. If you are required to file a return, a negligence penalty or other sanction may be
imposed on you if an amount of tax credit exceeding the amount reported on this form is
claimed on your income tax return.”
• Form 3921: Copy B — “This is important tax information and is being furnished to the IRS.
If you are required to file a return, a negligence penalty or other sanction may be imposed
on you if this item is required to be reported and the IRS determines that it has not been
reported.” Copy C — “This copy should be retained by the corporation whose stock has been
transferred under Section 422(b).”
• Form 3922: Copy B — “This is important tax information and is being furnished to the IRS.”
Copy C — “This copy should be retained by the corporation.”
• Form 5498: Copy B — “This information is being furnished to the IRS.” Note. If you do
not provide another statement to the participant because no contributions were made for the
year, the statement of the fair market value, and any required minimum distribution of the
account, must contain this legend and a designation of which information is being provided
to the IRS.
• Forms 5498-ESA, 5498-QA, and 5498-SA: Copy B — “This information is being furnished
to the IRS.”
Section 4.5 – Miscellaneous Instructions for Copies B, C, D, 1, and 2
4.5.1
Copies
Copies B, C, and in some cases D, 1, and 2 are included in the official assembly for the convenience
of the filer. You are not legally required to include all these copies with the privately printed
substitute forms. Furnishing Copy B, and in some cases Copy C, will satisfy the legal requirement
to provide statements of information to form recipients.
Note. If an amount of federal income tax withheld is shown on Form 1099-R or W-2G, Copy B (to
be attached to the tax return) and Copy C must be furnished to the recipient. Copy D (Form W-2G)
may be used for payer records. Only Copy A should be filed with the IRS.
4.5.2
Arrangement
of Assembly
Copy A (“For Internal Revenue Service Center”) of all forms must be on top. The rest of the
assembly must be arranged, from top to bottom, as follows.
FormTitle
1098Copy B “For Payer/Borrower”; Copy C “For Recipient/Lender.”
1098-CCopy B “For Donor”; Copy C “For Donor’s Records”; Copy D “For
Donee.”
1098-FCopy B “For Payer”; Copy C “For Filer.”

Bulletin No. 2024–30 147 July 22, 2024
FormTitle
1098-MACopy B “For Homeowner”; Copy C “For Filer.”
1098-QCopy B “For Participant”; Copy C “For Issuer.”
1099-ACopy B “For Borrower”; Copy C “For Lender.”
1097-BTC,
1099-PATR,
1099-Q, and
1099-QA
Copy B “For Recipient”; Copy C “For Payer.”
1099-CCopy B “For Debtor”; Copy C “For Creditor.”
1099-CAPCopy B “For Shareholder”; Copy C “For Corporation.”
1099-B,
1099-DIV,
1099-G,
1099-INT,
1099-MISC,
1099-NEC, and
1099-OID
Copy 1 “For State Tax Department”; Copy B “For Recipient”; Copy 2 “To
be filed with recipient’s state income tax return, when required.”
1099-KCopy 1 “For State Tax Department”; Copy B “For Payee”; Copy 2 “To be
filed with the recipient’s state income tax return, when required.”
1099-LSCopy B “For Payment Recipient”; Copy C “For Issuer”; Copy D “For
Acquirer.”
1099-LTCCopy B “For Policyholder”; Copy C “For Insured”; Copy D “For Payer.”
1099-RCopy 1 “For State, City, or Local Tax Department”; Copy B “Report this
income on your federal tax return. If this form shows federal income tax
withheld in box 4, attach this copy to your return.”; Copy C “For Recip-
ient’s Records”; Copy 2 “File this copy with your state, city, or local
income tax return, when required.”
1099-SCopy B “For Transferor”; Copy C “For Filer.”
1099-SACopy B “For Recipient”; Copy C “For Trustee/Payer.”
1099-SBCopy B “For Seller”; Copy C “For Issuer.”
3921Copy B “For Employee”; Copy C “For Corporation”; Copy D “For Trans-
feror.”
3922Copy B “For Employee”; Copy C “For Corporation.”
W-2GCopy 1 “For State, City, or Local Tax Department”; Copy B “Report this
income on your federal tax return. If this form shows federal income tax
withheld in box 4, attach this copy to your return.”; Copy C “For W
inner’s
Records”; Copy 2 “Attach this copy to your state, city, or local income tax
return, if required.”; Copy D “For Payer.”
1042-SCopy B “For Recipient”; Copy C “For Recipient” and “Attach to any fed-
eral tax return you file”; Copy D “For Recipient” and “Attach to any state
tax return you file”
4.5.3
Perforations
Instructions for perforation of forms can be found in Section 2.1.9.

July 22, 2024 148 Bulletin No. 2024–30
Section 4.6 – Electronic Delivery of Recipient Statements
4.6.1
Electr
onic Recipient
Statements
If you are required to furnish a written statement (Copy B or an acceptable substitute) to a recipient,
then you may furnish the statement electronically instead of on paper. This includes furnishing
the statement to recipients of Forms 1098, 1098-E, 1098-F, 1098-MA, 1098-Q, 1098-T, 1099-
A, 1099-B, 1099-C, 1099-CAP, 1099-DIV, 1099-G, 1099-H, 1099-INT, 1099-K, 1099-LS, 1099-
LTC, 1099-MISC, 1099-NEC, 1099-OID, 1099-PATR, 1099-Q, 1099-QA, 1099-R, 1099-S, 1099-
SA, 1099-SB, 1042-S, 3921, 3922, 5498, 5498-ESA, 5498-QA, and 5498-SA. It also includes
Form W-2G (except for horse and dog racing, jai alai, sweepstakes, wagering pools, and lotteries).
Note. Until further guidance is issued, you cannot furnish Form 1098-C electronically. Perforation
(see Section 2.1.9) does not apply to printouts of copies of forms that are furnished electronically
to recipients. However, recipients should be cautioned to carefully separate the copies.
If you meet the requirements listed in Sections 4.6.2 and 4.6.3, you are treated as furnishing the
statement timely.
4.6.2
Consent
The recipient must consent in the affirmative to receiving the statement electronically and not
have withdrawn the consent before the statement is furnished. The consent by the recipient must
be made electronically in a way that shows that the recipient can access the statement in the
electronic format in which it will be furnished. You must notify the recipient of any hardware
or software changes prior to furnishing the statement. A new consent to receive the statement
electronically is required after the new hardware or software is put into service. Prior to furnishing
the statements electronically, you must provide the recipient a statement with the following
statements prominently displayed.
• If the recipient does not consent to receive the statement electronically, a paper copy will be
provided.
• The scope and duration of the consent. For example, whether the consent applies to every
year the statement is furnished or only for the January 31, 2025 (February 15 for Forms
1099-B, 1099-S, and 1099-MISC with payments reported in box 8 or 10), due date immedi-
ately following the date of the consent.
• How to obtain a paper copy after giving consent.
• How to withdraw the consent. The consent may be withdrawn at any time by furnishing the
withdrawal in writing (electronically or on paper) to the person whose name appears on
the statement. Confirmation of the withdrawal will also be in writing (electronically or on
paper).
• Notice of termination. The notice must state under what conditions the statements will no
longer be furnished to the recipient.
• Procedures to update the recipient’s information.
• A description of the hardware and software required to access, print, and retain a statement,
and a date the statement will no longer be available on the website.

Bulletin No. 2024–30 149 July 22, 2024
4.6.3
Format, Posting, and
Notification
Additionally, you must:
• Ensure the electronic format contains all the required information and complies with the
guidelines in this document;
• Post, on or before the January 31, 2025 (February 15 for Forms 1099-B, 1099-S, and 1099-
MISC with payments reported in box 8 or 10), due date, the applicable statement on a web-
site accessible to the recipient through October 17 of that year; and
• Inform the recipient, electronically or by mail, of the posting and how to access and print the
statement.
For more information, see Regulations section 31.6051-1(j).
For electronic furnishing of:
• Forms 1098-E and 1098-T, see Regulations sections 1.6050S-2 and 1.6050S-4;
• Form 1099-K, see Regulations section 1.6050W-2;
• Forms 1099-QA and 5498-QA, see Regulations section 1.529A-7;
• Forms 1099-R, 1099-SA, 1099-Q, 5498, 5498-ESA, and 5498-SA, see Notice 2004-10,
2004-1 C.B. 433; and
• Form 1042-S, see Regulations section 1.1461-1(c)(1)(i).
Part 5
Additional Instructions for Substitute Forms 1097- BTC, 1098, 1099,
5498, W-2G, and 1042-S
Section 5.1 – Paper Substitutes for Form 1042-S
5.1.1
Paper
Substitutes
Paper substitutes of Copies A, B, C, and D must be identical to the Form 1042-S and may be
privately printed without prior approval from the IRS.
Caution. On the bottom of Copy B, left align the following text: (keep for your records), and
right align the following text: Form 1042-S (2024).
Note. Copies A, B, C, and D of Form 1042-S may not contain multiple income types for the same
recipient, that is, multiple rows of the top boxes 1–11 of the form.
5.1.2
Revisions
Form 1042-S is subject to annual review and possible change. Withholding agents and form
suppliers are cautioned against overstocking supplies of the privately printed substitutes.
5.1.3
Obtaining Copies
Copies of the official form for the reporting year may be obtained from most IRS offices. The IRS
provides only cut sheets of these forms. Continuous fan-fold/pin-fed forms are not provided.

July 22, 2024 150 Bulletin No. 2024–30
5.1.4
Instructions for
Withholding Agents
• Only original forms may be filed with the IRS. Photocopies are not acceptable.
• The term “Recipient’s U.S. TIN” for an individual means the SSN, ITIN, or ATIN, consist-
ing of nine digits separated by hyphens as follows: 000-00-0000; for all other recipients,
it means the EIN or qualified intermediary employer identification number (QI-EIN). The
QI-EIN designation includes a withholding foreign partnership employer identification num-
ber (WP-EIN), and a withholding foreign trust employer identification number (WT-EIN).
The EIN, QI-EIN, WP-EIN, and WT-EIN consist of nine digits separated by a hyphen as fol-
lows: 00-0000000. The TIN must be in one of these formats. Note. Digits must be separated
by hyphens on paper statements in the formats listed.
• The term “Recipient’s GIIN” means the global intermediary identification number (GIIN)
assigned to a recipient that is a participating foreign financial institution (FFI) (including
a reporting Model 2 FFI), registered deemed-compliant FFI (including a reporting Model 1
FFI), or other entity for chapter 4 purposes.
Note. A GIIN consists of nineteen characters as follows: XXXXXX.XXXXX.XX.XXX (6
characters followed by a period, 5 characters followed by a period, 2 characters followed by
a period, and 3 final characters).
• Withholding agents are requested to type or machine print whenever possible, provide qual-
ity data entries on the forms (that is, use black ink and insert data in the middle of blocks well
separated from other printing and guidelines), and take other measures to guarantee a clear,
sharp image. Withholding agents are not required, however, to acquire special equipment
solely for the purpose of preparing these forms.
• The “UNIQUE FORM IDENTIFIER,” “AMENDED,” and “AMENDMENT NO.” boxes
must be printed at the top center of the form under the title.
• Substitute forms prepared in continuous or strip form must be burst and stripped to conform
to the size specified for a single form before they are filed with the IRS. The dimensions are
found in Section 5.1.5. Computer cards are acceptable, provided they meet all requirements
regarding layout, content, and size.
• The OMB number must be printed in the format “OMB No. 1545-XXXX.” Use the appropri-
ate OMB number from the most recent revision of the original IRS form.
5.1.5
Substitute Form 1042-S
Format Requirements
PropertySubstitute Form 1042-S Format Requirements
PrintingPrivately printed substitute Forms 1042-S must be exact replicas of the
official forms with respect to layout and content. The GPO symbol must
be deleted. The exact dimensions are found below. The Cat. No. must
be removed and replaced with the form printer’s EIN or the vendor code
(preferred). See Section 2.1.10.
Box EntriesOnly one type of income may be represented on Copies A, B, C, and
D submitted to the IRS or furnished to recipients. All boxes on Copy A
filed with the IRS, and Copies B, C, and D furnished to recipients on the
substitute form must conform to the official IRS form.
Color and Quality
of Ink
All printing must be in high quality nongloss black ink.

Bulletin No. 2024–30 151 July 22, 2024
PropertySubstitute Form 1042-S Format Requirements
TypographyType must be substantially identical in size and shape to correspond-
ing type on the official form. All rules on the document are either 1 point
(0.015 inch) or 3 point (0.045 inch). Vertical rules must be parallel to the
left edge of the document; horizontal rules must be parallel to the top
edge.
AssemblyIf all four parts are present, the parts of the assembly shall be arranged
from top to bottom as follows: Copy A (Original) “for Internal Revenue
Service”; and Copies B, C, and D “for Recipient.”
Color Quality of
Paper
Paper for Copy A must be white chemical wood bond, or equivalent,
20 pounds (basis 17 x 22-500), plus or minus 5% (0.05); or offset book
paper, 50 pounds (basis 25 x 38-500). No optical brighteners may be
added to the pulp or paper during manufacture. The paper must consist
of principally bleached chemical wood pulp or recycled printed paper. It
must also be suitably sized to accept ink without feathering.
Dimensions• The dimensions for substitute Copies A, B, C, and D must match the
IRS Form 1042-S in size and format.
•
The official form is 8 inches wide x 11 inches deep, exclusive of a
1
/2- inch
snap stub on the left side of the form. The snap feature is not required on
substitutes.
• Copies A, B, C, and D must conform to the official IRS form. No
size variations are permitted.
Other CopiesCopies B, C, and D must be furnished for the convenience of payees
who must send a copy of the form with other federal and state returns
they file.
Section 5.2 – OMB Requirements for All Forms in This Revenue Procedure
5.2.1
OMB Requir
ements
The Paperwork Reduction Act (the Act) of 1995 (P. L. 104-13) requires the following.
• OMB approves all IRS tax forms that are subject to the Act. Each IRS form contains (in or
near the upper right corner) the OMB approval number, if any. (The official OMB numbers
may be found on the official IRS printed forms and are also shown on the forms in the exhib-
its in Part 6.)
• Each IRS form (or its instructions) states:
1. Why the IRS needs the information,
2. How it will be used, and
3. Whether or not the information is required to be furnished to the IRS.
This information must be provided to any users of official or substitute IRS forms or instructions.
5.2.2
Substitute Form
Requir
ements
The OMB requirements for substitute IRS forms are:
• Any substitute form or substitute statement to a recipient must show the OMB number as it
appears on the official IRS form; and

July 22, 2024 152 Bulletin No. 2024–30
• For Copy A, the OMB number must appear exactly as shown on the official IRS form.
For any copy other than Copy A, the OMB number must use one of the following formats.
1. OMB No. 1545-xxxx (preferred).
2. OMB # 1545-xxxx (acceptable).
Caution. These requirements do not apply to substitute Forms 1042-S. See Section 5.1.4.
5.2.3
Requir
ed Explanation to
Users
All substitute forms must state the Privacy Act and Paperwork Reduction Act Notice as listed in
Section 2.1.10.
If no instructions are provided to users of your forms, you must furnish them with the exact text of
the Privacy Act and Paperwork Reduction Act Notice.
Section 5.3 – Ordering Forms and Instructions
You can order official IRS Forms (Forms 1096, 1098, 1099, W-2G, 1042-S, and most other forms
mentioned in this publication), instructions, and information copies of federal tax material by
going to IRS.gov/OrderForms.
Note. Some forms on the Internet are intended as information only and may not be submitted as
an official IRS form (for example, most Forms 1099, W-2, and W-3). Unless otherwise instructed,
Form 1096 and Copy A of 1098 series, 1099 series, 5498 series, and Forms 3921 and 3922 cannot
be used for filing with the IRS when printed from a conventional printer. These forms contain
drop-out ink requirements as described in Part 2 of this publication.
Exception. Forms 1097-BTC, 1098-C, 1098-MA, 1099-CAP, 1099-LTC, 1099-Q, 1099-QA,
1099-SA, 3922, 5498-ESA, 5498-QA, 5498-SA, and 1042-S can be printed in black ink as
specified in Sections 2.1.1 and 5.1.5.
Section 5.4 – Effect on Other Revenue Procedures
5.4.1
Other Revenue Procedures
Revenue Procedure 2023-30, 2023-40 I.R.B. 995, dated October 2, 2023, is superseded by this
revenue procedure.

Bulletin No. 2024–30 153 July 22, 2024
Part 6
Exhibits
Section 6.1 – Exhibits of Forms in This Revenue Procedure
6.1.1
Purpose
Exhibits A through CC illustrate some of the specifications that were discussed earlier in this
revenue procedure. The dimensions apply to the actual size forms, but the exhibits have been
reduced in size.
Generally, the illustrated dimensions apply to all like forms. For example, Exhibit E shows 11.00
inches from the top edge to the bottom edge of Form 1098-E and 0.85 inch between the bottom
rule of the top form and the top rule of the second form on the page. These dimensions apply to all
forms that are printed 3-to-a-page.
Exhibit B contains the general measurements for forms printed 2-to-a-page. All 2-to-a-page forms,
except Form 1099-B, are 4.5 inches in height within the border lines. Form 1099-B is 4.67 inches
in height within the border lines.
Exhibit E contains the general measurements for forms printed 3-to-a-page. All 3-to-a-page forms
are 2.83 inches in height within the border lines.
The printed area of all forms is 7.3 inches wide.
All of the exhibits in this publication were updated to include all of the 2024 revisions for those
forms that have been revised.
6.1.2
Guidelines
Keep in mind the following guidelines when printing substitute forms.
• Closely follow the specifications to avoid delays in processing the forms.
• Always use the specifications as outlined in this revenue procedure and illustrated in the
exhibits.
• Do not add the text line “Do Not Cut or Separate Forms on This Page” to the bottom form.
This will be inconsistent with the specifications.
6.2
Exhibits
The following exhibits provide specifications for the forms listed in Section 1.1.2. Exhibits A, B,
and E contain the general measurements for all of the forms. The remaining exhibits represent the
images and may contain unique measurements as required by the forms.

July 22, 2024 154 Bulletin No. 2024–30
Exhibit A
Form 1096

Bulletin No. 2024–30 155 July 22, 2024

Exhibit B
Form 1097-BTC

July 22, 2024 156 Bulletin No. 2024–30
Exhibit C
Form 1098

Bulletin No. 2024–30 157 July 22, 2024
Exhibit D
Form 1098-C

July 22, 2024 158 Bulletin No. 2024–30
Exhibit E
Form 1098-E

Bulletin No. 2024–30 159 July 22, 2024
Exhibit F
Form 1098-F

July 22, 2024 160 Bulletin No. 2024–30
Exhibit G
Form 1098-MA

Bulletin No. 2024–30 161 July 22, 2024
Exhibit H
Form 1098-Q

July 22, 2024 162 Bulletin No. 2024–30
Exhibit I
Form 1098-T

Bulletin No. 2024–30 163 July 22, 2024
Exhibit J
Form 1099-A

July 22, 2024 164 Bulletin No. 2024–30
Exhibit K
Form 1099-B

Bulletin No. 2024–30 165 July 22, 2024
Exhibit L
Form 1099-C

July 22, 2024 166 Bulletin No. 2024–30
Exhibit M
Form 1099-DIV

Bulletin No. 2024–30 167 July 22, 2024
Exhibit N
Form 1099-G

July 22, 2024 168 Bulletin No. 2024–30
Exhibit O
Form 1099-INT

Bulletin No. 2024–30 169 July 22, 2024
Exhibit P
Form 1099-K

July 22, 2024 170 Bulletin No. 2024–30
Exhibit Q
Form 1099-LS

Bulletin No. 2024–30 171 July 22, 2024
Exhibit R
Form 1099-MISC

July 22, 2024 172 Bulletin No. 2024–30
Exhibit S
Form 1099-NEC

Bulletin No. 2024–30 173 July 22, 2024
Exhibit T
Form 1099-OID

July 22, 2024 174 Bulletin No. 2024–30
Exhibit U
Form 1099-PATR

Bulletin No. 2024–30 175 July 22, 2024
Exhibit V
Form 1099-Q

July 22, 2024 176 Bulletin No. 2024–30
Exhibit W
Form 1099-R

Bulletin No. 2024–30 177 July 22, 2024
Exhibit X
Form 1099-S

July 22, 2024 178 Bulletin No. 2024–30
Exhibit Y
Form 1099-SB

Bulletin No. 2024–30 179 July 22, 2024
Exhibit Z
Form 3921

July 22, 2024 180 Bulletin No. 2024–30
Exhibit AA
Form 5498

Bulletin No. 2024–30 181 July 22, 2024
Exhibit BB
Form W-2G

July 22, 2024 182 Bulletin No. 2024–30
Exhibit CC
Form 1042-S

Bulletin No. 2024–30 183 July 22, 2024
26 CFR 601.204: Changes in accounting periods
and in methods of accounting.
(Also: Part I, §§ 446, 166; 1.166-2.)
Rev. Proc. 2024-30
SECTION 1. PURPOSE
This revenue procedure modifies Rev.
Proc. 2024-23, 2024-23 I.R.B. 1334,
to provide procedures under § 446 of
the Internal Revenue Code (Code) and
§ 1.446-1(e) of the Income Tax Regula-
tions for obtaining automatic consent of
the Commissioner of Internal Revenue
(Commissioner) to change methods of
accounting to the Allowance Charge-off
Method described in a notice of proposed
rulemaking (REG-121010-17) containing
proposed regulations under section 166
(proposed § 1.166-2).
1
SECTION 2. BACKGROUND
.01 On December 28, 2023, the
Department of the Treasury (Treasury)
and the Internal Revenue Service (IRS)
published proposed § 1.166-2 in the Fed-
eral Register (88 FR 89636). Proposed
§ 1.166-2 would provide a method to
determine when a debt instrument held
by a regulated financial company (as
defined in proposed § 1.166-2(d)(4)(ii))
or a member of a regulated financial
group (as defined in proposed § 1.166-
2(d)(4)(iii)) is conclusively presumed
to be worthless, in whole or in part, for
purposes of the bad debt rules in § 166
(Allowance Charge-off Method). See pro-
posed § 1.166–2(d)(1). Under the Allow-
ance Charge-off Method, a debt instru-
ment would be conclusively presumed to
be worthless, in whole or in part, to the
extent that the amount of any charge-off
under proposed § 1.166-2(d)(1)(i) or (ii)
is claimed as a deduction under § 166 on
the relevant Federal income tax return for
the taxable year in which the charge-off
takes place.
.02 Proposed § 1.166-2 generally
would apply to charge-offs made by a reg-
ulated financial company or a member of a
regulated financial group on its applicable
financial statement that occur in taxable
years ending on or after the date the final
regulations are published in the Federal
Register. However, until the date the Trea-
sury decision adopting proposed § 1.166-2
is published in the Federal Register, a reg-
ulated financial company or a member of
a regulated financial group may rely on
proposed § 1.166-2 for charge-offs made
on its applicable financial statement that
occur in taxable years ending on or after
December 28, 2023, and before the final
regulations are published in the Federal
Register.
.03 After the proposed regulations
were published, commenters requested
that the Treasury Department and the
IRS provide guidance on how taxpayers
may change to the Allowance Charge-off
Method for taxable years ending on or
after December 28, 2023. In response to
those comments, this revenue procedure
allows a regulated financial company or
a member of a regulated financial group
to change its method of accounting to the
Allowance Charge-off Method using the
automatic method change procedures of
Rev. Proc. 2015-13, 2015-5 I.R.B. 419,
as clarified and modified by Rev. Proc.
2015-33, 2015-24 I.R.B. 1067, and as
modified by Rev. Proc. 2021-34, 2021-
35 I.R.B. 337; by Rev. Proc. 2021-26,
2021-22 I.R.B. 1163; by Rev. Proc. 2017-
59, 2017-48 I.R.B. 543; and by section
17.02(b) and (c) of Rev. Proc. 2016-1,
2016-1 I.R.B. 1.
.04 Except as otherwise provided by
the Code or the regulations, § 446(e)
and § 1.446-1(e)(2) require a taxpayer to
secure the consent of the Commissioner
before changing a method of account-
ing for Federal income tax purposes.
Section 1.446-1(e)(3)(i) states, in part,
that except as otherwise provided under
the authority of § 1.446-1(e)(3)(ii), to
secure the Commissioner’s consent to a
taxpayer’s change in method of account-
ing, the taxpayer generally must file a
Form 3115, Application for Change in
Accounting Method, with the Commis-
sioner during the taxable year in which
the taxpayer wants to make the change
in method of accounting. Section 1.446-
1(e)(3)(ii) authorizes the Commissioner
to prescribe administrative procedures
under which taxpayers will be permit-
ted to change their method of account-
ing. The administrative procedures will
prescribe those terms and conditions
necessary to obtain the Commissioner’s
consent to effect the change and to pre-
vent amounts from being duplicated or
omitted.
.05 Rev. Proc. 2015-13 provides the
general procedures by which a taxpayer
may obtain automatic consent of the
Commissioner to a change in method
of accounting described in the List of
Automatic Changes. Rev. Proc. 2024-23
contains the current List of Automatic
Changes.
.06 Section 3 of this revenue procedure
modifies Rev. Proc. 2024-23 to provide
a new automatic change in method of
accounting for a taxpayer to change its
method of accounting to the Allowance
Charge-off Method described in proposed
§ 1.166-2(d)(1).
SECTION 3. MODIFICATION TO REV.
PROC. 2024-23
Section 4 of Rev. Proc. 2024-23 is
modified to add new section 4.03 to read
as follows:
.03 Change to the Allowance Charge-
off Method.
(1) Description of change.
(a) Applicability. This change applies
to a regulated financial company (as
defined in proposed § 1.166-2(d)(4)(ii)) or
a member of a regulated financial group
(as defined in proposed § 1.166-2(d)(4)
(iii)) that wants to change its method of
accounting to the Allowance Charge-off
Method described in proposed § 1.166-
2(d)(1). See Bad Debt Deductions for
Regulated Financial Companies and
Members of Regulated Financial Groups,
88 FR 89636 (Dec. 28, 2023).
(b) Inapplicability. This change
does not apply to a bank (as defined in
§ 581) that wants to change its method
of accounting for bad debts from the §
585 reserve method to the Allowance
Charge-off Method described in pro-
posed § 1.166-2(d)(1). Any change to the
Allowance Charge-off Method requested
by such a bank must be made under the
1
Unless otherwise specified, all “section” or “§” references are to sections of the Code, the existing Income Tax Regulations (26 CFR part 1), or provisions of proposed § 1.166-2.

July 22, 2024 184 Bulletin No. 2024–30
non-automatic change procedures in Rev.
Proc. 2015-13.
(2) Certain eligibility rule inapplica-
ble. The eligibility rule in section 5.01(1)
(f) of Rev. Proc. 2015-13 does not apply to
a change described in section 4.03(1)(a) of
this revenue procedure for the taxpayer’s
first or second taxable year ending on or
after December 28, 2023.
(3) Manner of making change.
(a) Charge-offs on or after beginning of
the year of change. This change is made on
a cut-off basis and only applies to charge-
offs (as defined in proposed § 1.166-2(d)
(4)(i)) made by a regulated financial com-
pany or a member of a regulated financial
group on its applicable financial statement
(as defined in proposed § 1.166-2(d)(4)
(viii)) that occur on or after the beginning
of the year of change. Accordingly, a §
481(a) adjustment is neither permitted nor
required.
(b) Charge-offs prior to the year of
change. Any charge-offs that occurred
prior to the year of change are accounted
for under the taxpayer’s former method
of accounting, and any charge-offs that
occur in the year of change and in sub-
sequent taxable years are accounted for
under the taxpayer’s method of account-
ing for which consent is granted. In no
event may a taxpayer take a deduction
under its new method of accounting for
any amount of debt previously deducted
as worthless under its former method of
accounting.
(4) Revocation of conformity election
under existing § 1.166-2(d)(3). A regu-
lated financial company or a member of a
regulated financial group that previously
made a conformity election under § 1.166-
2(d)(3) and that changes its method of
accounting under this section 4.03 is
treated as having revoked its conformity
election pursuant to § 1.166-2(d)(3)(iv).
(5) Contact information. For further
information regarding a change under this
section, contact Jason Kristall at (202)
317-6945 (not a toll-free number).
(6) Designated automatic accounting
method change number. The designated
automatic accounting method change
number for a change under this section
4.03 is “272.”
SECTION 4. EFFECTIVE DATE
This revenue procedure is effective for
charge-offs made by a regulated finan-
cial company or a member of a regulated
financial group on its applicable financial
statement that occur in taxable years end-
ing on or after December 28, 2023.
SECTION 5. EFFECT ON OTHER
DOCUMENTS
This revenue procedure modifies Rev.
Proc. 2024-23.
SECTION 6. DRAFTING
INFORMATION
The principal authors of this revenue
procedure are Stephanie D. Floyd and
Jason D. Kristall of the Office of Associ-
ate Chief Counsel (Financial Institutions
and Products). For further information
regarding this revenue procedure, contact
Stephanie D. Floyd at (202) 317-7053 or
Jason D. Kristall at (202) 317-6945 (not
toll-free numbers).

Bulletin No. 2024–30 i July 22, 2024
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein. Thus,
if an earlier ruling held that a principle
applied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below).
Clarified is used in those instances
where the language in a prior ruling is
being made clear because the language
has caused, or may cause, some confu-
sion. It is not used where a position in a
prior ruling is being changed.
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them.
Modified is used where the substance
of a previously published position is being
changed. Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position. (Compare
with amplified and clarified, above).
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions.
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations. A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted.
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling.
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings).
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations. The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc.,
that were previously published over a
period of time in separate rulings. If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used. For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previously
published ruling in a new ruling that is
self contained. In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings. After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series.
Suspended is used in rare situations
to show that the previous published rul-
ings will not be applied pending some
future action such as the issuance of new
or amended regulations, the outcome of
cases in litigation, or the outcome of a
Service study.
Abbreviations
The following abbreviations in current
use and formerly used will appear in
material published in the Bulletin.
A—Individual.
Acq.—Acquiescence.
B—Individual.
BE—Beneficiary.
BK—Bank.
B.T.A.—Board of Tax Appeals.
C—Individual.
C.B.—Cumulative Bulletin.
CFR—Code of Federal Regulations.
CI—City.
COOP—Cooperative.
Ct.D.
—Court Decision.
CY—County.
D—Decedent.
DC—Dummy Corporation.
DE—Donee.
Del. Order—Delegation Order.
DISC—Domestic International Sales Corporation.
DR—Donor.
E—Estate.
EE—Employee.
E.O.—Executive Order.
ER—Employer.
ERISA—Employee Retirement Income Security Act.
EX—Executor.
F—Fiduciary.
FC—Foreign Country.
FICA—Federal Insurance Contributions Act.
FISC—Foreign International Sales Company.
FPH—Foreign Personal Holding Company.
F.R.—Federal Register.
FUTA—Federal Unemployment Tax Act.
FX—Foreign corporation.
G.C.M.—Chief Counsel’s Memorandum.
GE—Grantee.
GP—General Partner.
GR—Grantor.
IC—Insurance Company.
I.R.B.—Internal Revenue Bulletin.
LE—Lessee.
LP—Limited Partner.
LR—Lessor.
M—Minor.
Nonacq.—Nonacquiescence.
O—Organization.
P—Parent Corporation.
PHC—Personal Holding Company.
PO—Possession of the U.S.
PR—Partner.
PRS—Partnership.
PTE—Prohibited Transaction Exemption.
Pub. L.—Public Law.
REIT—Real Estate Investment Trust.
Rev. Proc.—Revenue Procedure.
Rev. Rul.—Revenue Ruling.
S—Subsidiary.
S.P.R.—Statement of Procedural Rules.
Stat.—Statutes at Large.
T—Target Corporation.
T.C.—Tax Court.
T.D.—Treasury Decision.
TFE—Transferee.
TFR—Transferor.
T.I.R.—Technical Information Release.
TP—Taxpayer.
TR—Trust.
TT—Trustee.
U.S.C.—United States Code.
X—Corporation.
Y—Corporation.
Z—Corporation.

July 22, 2024 ii Bulletin No. 2024–30
Numerical Finding List
1
Bulletin 2024–30
Announcements:
2024-26, 2024-27 I.R.B. 14
2024-27, 2024-27 I.R.B. 14
2024-28, 2024-28 I.R.B. 39
2024-29, 2024-29 I.R.B. 71
Notices:
2024-47, 2024-27 I.R.B. 1
2024-52, 2024-27 I.R.B. 2
2024-53, 2024-27 I.R.B. 4
2024-54, 2024-28 I.R.B. 24
2024-55, 2024-28 I.R.B. 31
2024-56, 2024-29 I.R.B. 64
2024-57, 2024-29 I.R.B. 67
2024-58, 2024-30 I.R.B. 120
Proposed Regulations:
REG-124593-23, 2024-28 I.R.B. 40
Revenue Procedures:
2024-26, 2024-27 I.R.B. 7
2024-29, 2024-30 I.R.B. 121
2024-30, 2024-30 I.R.B. 183
Revenue Rulings:
2024-13, 2024-28 I.R.B. 18
2024-14, 2024-28 I.R.B. 18
Treasury Decisions:
10002, 2024-29 I.R.B. 56
9999, 2024-30 I.R.B. 72
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin
2024–52, dated December 30, 2024.

Bulletin No. 2024–30 iii July 22, 2024
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2024–30
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc., published in Internal Revenue Bulletins 2024–27 through 2024–52 is in Internal Revenue Bulletin
2024–52, dated December 30, 2024.

Internal Revenue Service
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