S. 4700

[Congressional Bills 119th Congress]
[From the U.S. Government Publishing Office]
[S. 4700 Introduced in Senate (IS)]

<DOC>

119th CONGRESS
2d Session
S. 4700

To amend the Internal Revenue Code of 1986 to allow a credit against 
income tax for qualified conservation contributions which include 
National Scenic Trails.

_______________________________________________________________________

IN THE SENATE OF THE UNITED STATES

June 8, 2026

Mr. Blumenthal (for himself, Mr. Murphy, Ms. Warren, and Mr. Van 
Hollen) introduced the following bill; which was read twice and 
referred to the Committee on Finance

_______________________________________________________________________

A BILL

To amend the Internal Revenue Code of 1986 to allow a credit against 
income tax for qualified conservation contributions which include 
National Scenic Trails.

Be it enacted by the Senate and House of Representatives of the 
United States of America in Congress assembled,

SECTION 1. SHORT TITLE.

This Act may be cited as the ``Complete America's Great Trails 
Act''.

SEC. 2. NATIONAL SCENIC TRAIL CONSERVATION CREDIT.

(a) In General.--Subpart B of part IV of subchapter A of chapter 1 
of the Internal Revenue Code of 1986 is amended by adding at the end 
the following new section:

``SEC. 30E. NATIONAL SCENIC TRAIL CONSERVATION CREDIT.

``(a) Allowance of Credit.--There shall be allowed as a credit 
against the tax imposed by this chapter for the taxable year an amount 
equal to the fair market value of any National Scenic Trail 
conservation contribution of the taxpayer for the taxable year.
``(b) National Scenic Trail Conservation Contribution.--For 
purposes of this section--
``(1) In general.--The term `National Scenic Trail 
conservation contribution' means any qualified conservation 
contribution--
``(A) to the extent the qualified real property 
interest with respect to such contribution includes a 
National Scenic Trail (or portion thereof) and its 
trail corridor, and
``(B) with respect to which the taxpayer makes an 
election under this section.
``(2) National scenic trail.--The term `National Scenic 
Trail' means any trail authorized and designated under section 
5 of the National Trails System Act (16 U.S.C. 1244).
``(3) Trail corridor.--
``(A) In general.--The term `trail corridor' means 
so much of the corridor of a trail as is--
``(i) subject to subparagraph (B), not less 
than 50 feet wide on each side of such trail, 
and
``(ii) not greater than 2,640 feet wide.
``(B) Exceptions.--
``(i) Less than 50 feet wide on a side of 
the trail.--In the case of an interest in real 
property of the taxpayer which includes less 
than 50 feet on either side of the trail, the 
trail corridor shall include the entire 
distance with respect to such interest on such 
side.
``(ii) Building and structures near the 
trail.--In the case of an interest in real 
property of the taxpayer which includes a 
residence or structure owned by the taxpayer 
which is located less than 50 feet from the 
trail, the trail corridor for the side of the 
trail on which the residence or structure is 
located shall include such distance from the 
trail as is determined appropriate by the 
taxpayer.
``(4) Qualified conservation contribution; qualified real 
property interest.--The terms `qualified conservation 
contribution' and `qualified real property interest' have the 
respective meanings given such terms by section 170(h), except 
that paragraph (2)(A) thereof shall be applied without regard 
to any qualified mineral interest (as defined in paragraph (6) 
thereof).
``(c) Special Rules.--
``(1) Fair market value.--Fair market value of any National 
Scenic Trail conservation contribution shall be determined in 
the same manner as qualified conservation contributions under 
section 170, except that in any case, to the extent 
practicable, fair market value shall be determined by reference 
to the highest and best use of the real property with respect 
to such contribution.
``(2) Election irrevocable.--An election under this section 
may not be revoked.
``(3) Denial of double benefit.--No deduction shall be 
allowed under this chapter with respect to any qualified 
conservation contribution with respect to which an election is 
made under this section.
``(d) Application With Other Credits.--
``(1) Business credit treated as part of general business 
credit.--So much of the credit which would be allowed under 
subsection (a) for any taxable year (determined without regard 
to this subsection) that is attributable to property used in a 
trade or business or held for the production of income shall be 
treated as a credit listed in section 38(b) for such taxable 
year (and not allowed under subsection (a)).
``(2) Personal credit.--For purposes of this title, the 
credit allowed under subsection (a) for any taxable year 
(determined after the application of paragraph (1)) shall be 
treated as a credit allowable under subpart A for such taxable 
year.
``(e) Carryforward of Unused Credit.--
``(1) In general.--If the credit allowable under subsection 
(a) exceeds--
``(A) the limitation imposed by section 26(a) for 
any taxable year, reduced by
``(B) the sum of the credits allowable under 
subpart A (other than this section) for the taxable 
year,
such excess shall be carried to the succeeding taxable year and 
added to the credit allowable under subsection (a) for such 
succeeding taxable year.
``(2) Limitation.--No credit may be carried forward under 
this subsection to any taxable year following the tenth taxable 
year after the taxable year in which the credit arose. For 
purposes of the preceding sentence, credits shall be treated as 
used on a first-in first-out basis.''.
(b) Continued Use Not Inconsistent With Conservation Purposes.--A 
contribution of an interest in real property shall not fail to be 
treated as a National Scenic Trail conservation contribution (as 
defined in section 30E(b) of the Internal Revenue Code of 1986) solely 
by reason of continued use of the real property, such as for 
recreational or agricultural use (including motor vehicle use related 
thereto), if, under the circumstances, such use does not impair 
significant conservation interests and is not inconsistent with the 
purposes of the National Trails System Act (16 U.S.C. 1241 et seq.).
(c) Study Regarding Efficacy of National Scenic Trail Conservation 
Credit.--
(1) In general.--The Secretary of the Interior shall, in 
consultation with the Secretary of the Treasury, study--
(A) the efficacy of the National Scenic Trail 
conservation credit under section 30E of the Internal 
Revenue Code of 1986 in completing, extending, and 
increasing the number of National Scenic Trails (as 
defined in section 30E(b) of such Code), and
(B) the feasibility and estimated costs and 
benefits of--
(i) making such credit refundable (in whole 
or in part), and
(ii) allowing transfer of such credit.
(2) Report.--Not later than 4 years after the date of the 
enactment of this Act, the Secretary of the Interior shall 
submit a report to Congress on the results of the study 
conducted under this subsection.
(d) Conforming Amendment.--The table of sections for subpart B of 
part IV of subchapter A of chapter 1 of such Code is amended by adding 
at the end the following new item:

``30E. National Scenic Trail conservation credit.''.
(e) Effective Date.--The amendments made by this section shall 
apply to contributions made after the date of the enactment of this 
Act.
<all>