Treasury Regulations · 26 CFR
§ 1.706-3. Items attributable to interest in lower-tier partnership.
Regulation text, no changes From the eCFR, current as of October 15, 2026. The eCFR is an authoritative but unofficial editorial compilation of the Code of Federal Regulations; the official text is the annual CFR on govinfo. Compare it with this section on ecfr.gov (external site) or the official annual CFR on govinfo (external site).
Regulation under 26 U.S.C. § 706
Cite as 26 CFR § 1.706-3
At a glance
Read from the text and its source citation. Not part of the regulation.
- Status
- In the current eCFR
- Issued
- June 28, 2024 by T.D. 9999
- Issued under
- 26 U.S.C. § 706
- Length
- 167 words · about 1 min to read
- Cross-references
- cites 2 Code sections and 2 regulations; cited by 1
¶(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.
[T.D. 9999, 89 FR 54327, June 28, 2024]
Cross-references
Computed from the citations in the text of 26 CFR.
Code sections it cites
Regulations it cites
- § 1.170A-14 Qualified conservation contributions.
- § 1.706-4 Determination of distributive share when a partner's interest varies.
Cited by 1 other regulation
Amendment history
From the source citation at the end of the section, newest first. T.D. is a Treasury decision; FR is the Federal Register.
- Issued by T.D. 9999 (89 FR 54327)
Where it sits in 26 CFR
- Subchapter A Income tax
- Part 1 Income taxes
- Partners and partnerships
Nearby sections
- § 1.705-2 Basis adjustments coordinating sections 705 and 1032.
- § 1.706-0 Table of contents.
- § 1.706-1 Taxable years of partner and partnership.
- § 1.706-2T Temporary regulations; question and answer under the Tax Reform Act of 1984.
- § 1.706-3 Items attributable to interest in lower-tier partnership.
- § 1.706-4 Determination of distributive share when a partner's interest varies.
- § 1.706-5 Taxable year determination.
- § 1.707-0 Table of contents.
- § 1.707-1 Transactions between partner and partnership.