Earlier this week the IRS issued final regulations implementing section 605 of the SECURE 2.0 Act of 2022, enacted as Division T of the Consolidated Appropriations Act, 2023, Public Law 117-328, 136 Stat. 4459, 5393 (Dec. 29, 2022). That provision amended Internal Revenue Code section 170 to limit the amount of a qualified conservation contribution by a partnership or S corporation to 2.5 times the basis in the relevant real property with certain exceptions, including if the pass-through entity had held the real property for more than three years. That provision also made certain related modifications to penalty and reporting requirements. Coverage: Journal of AccountancyLaw360 (subscription required).
Lloyd Mayer
