A Republican bill with no cosponsors
Last activity — Referred to the House Committee on Ways and Means.
In committee
Introduced and handed to a committee in the chamber it started in.
The committee holds it, and most bills are never heard from again. A hearing or a committee vote would be news; silence is the usual outcome, and it kills the bill without anyone voting against it.
Its path through Congress
- Introduced
- In Committee
What this bill would do
This bill creates a settlement program for disputes involving syndicated conservation easements. It tells the Treasury Secretary to set up this resolution program within 180 days of the law passing, in consultation with the National Taxpayer Advocate. During the period before the program starts, the Secretary cannot start new disputes, and the statute of limitations is paused. The bill sets specific rules for reducing penalties and handling ongoing court cases related to these easements. It also amends the Internal Revenue Code regarding the valuation of conservation easements and how extinguishment proceeds are handled. Finally, it requires regular reports to congressional committees on how the act is being implemented.
Yes· 3 of 6
- Scored +7
Would people with substantial wealth be better off under this?
High-net-worth individuals who participated in covered conservation easement transactions receive significant financial relief through reduced penalties and refunds.
- Scored +7
Would the very wealthiest people be better off under this?
Ultra-high-net-worth taxpayers involved in syndicated conservation easements benefit directly from favorable valuation rules and settlement provisions.
- Scored +6
Would high-income households be better off under this?
The bill provides substantial penalty reductions, settlement terms, and refunds relating to syndicated conservation easement transactions predominantly utilized by high-income investors.
The opposite
No question was scored the opposite.
Who it would affect, and how
Potential Positive Impacts for People
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Reduced Penalties for Certain Easements: Section 2(c)(1)(B) states that for covered transactions where the easement is not a qualified easement but the conservation purposes are substantially preserved, any deficiency, penalty, or interest amount must be reduced by at least 80 percent. This directly benefits taxpayers by significantly lowering the financial penalties they might otherwise owe.
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Refunds for Past Payments: Section 2(e) requires the Secretary to provide a payment to taxpayers who already reached a final disposition before this Act, covering the excess of what they paid in penalties, deficiencies, or interest compared to what they would owe under the new settlement terms. This puts money back into the pockets of people who settled earlier under harsher rules.
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Presumption of Appraisal Accuracy: Section 2(f)(1) and Section 4(a) establish a rebuttable presumption that the value of a conservation easement determined by a taxpayer's qualified appraisal is accurate. This protects everyday taxpayers by placing a high burden of proof (clear and convincing evidence) on the government if it wants to challenge the appraisal.
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Protection for Form 8886 Filings: Section 2(h) ensures that taxpayers who filed Form 8886 are conclusively presumed to have acted in good faith without actual knowledge of fraud. This prevents the government from using these specific tax filings as primary evidence to deny relief, delay refunds, or penalize individuals.
Potential Negative Impacts for People
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Strict Rules for Proving Fraud Exceptions: Section 2(c)(2) outlines strict criteria for when the government can claim a taxpayer knowingly participated in fraud, such as requiring direct and documented evidence of intentional conduct. While this protects innocent taxpayers, critics might view it as creating a high hurdle for the government to hold bad actors accountable for abusive tax shelters.
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Potential Loss of Discretion for Tax Enforcement: Sections 2(b) and 2(c) restrict the Secretary from initiating new disputes and cap penalties across the board for certain categories of transactions. This limits the government's ability to fully investigate and penalize wealthy participants who may have abused syndicated conservation easements, potentially shifting a larger tax burden onto the general public.
Groups and Interests Ranking
Every group the model scored this bill for, from -10 to +10. Tap or hover a score for the reason it gave.
- Demographic And Interest Groups
- Would people with substantial wealth be better off under this? — High-net-worth individuals who participated in covered conservation easement transactions receive significant financial relief through reduced penalties and refunds. Would the very wealthiest people be better off under this? — Ultra-high-net-worth taxpayers involved in syndicated conservation easements benefit directly from favorable valuation rules and settlement provisions. Would high-income households be better off under this? — The bill provides substantial penalty reductions, settlement terms, and refunds relating to syndicated conservation easement transactions predominantly utilized by high-income investors. Would business owners be better off under this? — Business owners and partners involved in syndicated conservation easements benefit from reduced penalties and streamlined dispute resolution.
- Governance And Ideology
- Does this protect the right to fair treatment by the courts? — The bill establishes clear procedural protections, a rebuttable presumption of appraisal accuracy, and limits certain retroactive tax enforcement actions. Does this make what the government does easier for the public to see? — The bill requires the Secretary of the Treasury to submit regular implementation reports to congressional committees regarding the settlement program.
- 9/21/2026
- Referred to the House Committee on Ways and Means.
- Introduced in House