§ 1.706-3 - Items attributable to interest in lower-tier partnership.

§ 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 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 contribution at the time of day at which the qualified 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 allocations subject to this section.

(e) Applicability date. Paragraph (d) of this section applies to qualified conservation contributions made after December 29, 2022, and in partnership taxable years ending after December 29, 2022.

[TD 9999, 89 FR 54327, June 28, 2024]