What This Bill Does
This bill would create a special election for certain open partnership controversies involving donations of conservation easements, a tax issue that can affect the partnership’s deduction treatment and related liability. In practical terms, it targets unresolved disputes for partnerships that contributed land interests for conservation purposes and are still facing federal tax controversy. The measure is aimed at resolving those cases through an election mechanism rather than leaving them in prolonged dispute. It would matter most to partnerships, investors, landowners, and tax professionals dealing with conservation-easement filings and audits.
- Creates an election for certain open partnership controversies.
- Applies to disputes involving donations of conservation easements.
- Affects partnership-level federal tax treatment and case resolution.
- Moves the issue to the House Ways and Means Committee.
- Introduced by Rep. Mike Carey on June 23, 2026.
Who This Bill Affects
For most people, this bill would not change day-to-day taxes or benefits. Its effects would be concentrated on partnerships, landowners, and investors with open federal tax disputes tied to conservation-easement donations, who could gain a defined route to resolve those cases instead of continuing with uncertain controversy and legal costs. If you are not involved in one of those transactions, the direct personal impact would be minimal.
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- Bill
- HR 9398
- Congress
- 119th Congress
- Official title
- To provide an election to resolve certain open partnership controversies involving donations of conservation easements.
- Policy area
- Economy & Finance
- Latest action
- Referred to the House Committee on Ways and Means. (June 23, 2026)
- Last updated
- June 24, 2026
Who Supports & Opposes This
- Partnerships and investors with open tax disputes They may favor a clear election because it can provide closure, reduce litigation uncertainty, and limit continuing legal and accounting costs tied to unresolved conservation-easement cases.
- Landowners and conservation-focused donors They may see the bill as a way to preserve the underlying conservation purpose while giving taxpayers a practical process to resolve contested filings without years of prolonged dispute.
- Tax professionals and compliance advisers A defined resolution mechanism can simplify administration, make outcomes more predictable, and reduce the burden of managing complex partnership-level controversies.
- Tax enforcement advocates They may argue that special relief for certain easement-related partnership disputes can weaken deterrence and make it harder to police abusive or inflated charitable deductions.
- Fiscal watchdog groups They may object that a targeted election could reduce federal revenue or provide retroactive benefits to taxpayers involved in contentious transactions.
- Competing charitable and land-use stakeholders They may worry that the bill could reward a narrow category of taxpayers instead of applying a uniform rule to all disputed tax matters.
Key Implications
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““provide an election””
This means affected taxpayers would get a formal choice under the tax rules, rather than having every dispute resolved only through ordinary audit or court processes.
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““certain open partnership controversies””
The measure is aimed at unresolved cases that are still active, so the practical effect would be on taxpayers with pending partnership-level disputes.
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““donations of conservation easements””
The bill focuses on a specific kind of land-preservation transaction that has significant federal tax consequences for donors and partnerships.
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““open partnership controversies””
Because the issue is partnership-level, the consequences can affect multiple partners at once, including how deductions, liabilities, or settlements are allocated.
Latest Status
June 23, 2026
Referred to the House Committee on Ways and Means.
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