Qualified Conservation Contribution: Valuing Charitable Donations (2025 IRS Guide)

This guide covers “Qualified Conservation Contribution” within valuing charitable donations. The following material presents the IRS treatment of this topic, including the qualifications, exceptions, and examples in the source section. Read the rules alongside the facts of your own situation before deciding what to report, deduct, or document.

Adapted from Publication 561 (12/2025), Determining the Value of Donated Property, published by the Internal Revenue Service. This guide retains the source edition’s years, amounts, deadlines, and examples. It is guidance for that edition, not a statement that the same figures apply to every tax year.

Context for these rules

Generally, no deduction is allowed for a charitable contribution, not made in trust, of less than your entire interest in property. However, this does not apply to a transfer of less than your entire interest if it is a transfer of:

• A remainder interest in your personal residence or farm,

• An undivided part of your entire interest in property, or

• A qualified conservation contribution.

Qualified Conservation Contribution

A qualified conservation contribution is a contribution of a qualified real property interest to a qualified organization to be used only for conservation purposes as defined in section 170(h)(4).

Qualified organization.

For purposes of a qualified conservation contribution, a qualified organization is:

• A governmental unit;

• A publicly supported charitable, religious, scientific, literary, educational, etc., organization; or

• An organization that is controlled by and operated for the exclusive benefit of a governmental unit or a publicly supported charity.

The organization must also have a commitment to protect the conservation purposes of the donation and must have the resources to enforce the restrictions.

Note:

A qualified organization is one of a certain group of charities that qualifies under section 170(c) for an income tax charitable contribution deduction.

Conservation purposes.

Your contribution must be made only for one of the following conservation purposes.

• Preserving land areas for outdoor recreation by or for the education of the general public.

• Protecting a relatively natural habitat of fish, wildlife, or plants or a similar ecosystem.

• Preserving open space, including farmland and forest land, if it yields a significant public benefit. It must be either for the scenic enjoyment of the general public or under a clearly defined federal, state, or local governmental conservation policy.

• Preserving a historically important land area or a certified historic structure. There must be some visual public access to the property. Factors used in determining the type and amount of public access required include the historical significance of the property, the remoteness or accessibility of the site, and the extent to which intrusions on the privacy of individuals living on the property would be unreasonable.

Certified historic structures.

There are two types of buildings that may be certified historic structures: a National Register building and a registered historic district building. A National Register building and a historic district building can be certified by the Department of the Interior as a certified historic structure. A National Register building is an individual building that is listed in the National Register of Historic Places (“National Register”). If the building is the only building in the listing in the National Register, no certification is necessary by the Department of the Interior; the building is a certified historic structure. Alternatively, if the listing in the National Register consists of more than one building (for example, a house, a garage, a mill complex, etc.), the Secretary of the Interior must certify which of the multiple buildings is the certified historic structure.

A registered historic district building is an individual building that is located in a registered historic district and has been separately certified by the Secretary of the Interior as a certified historic structure. The mere listing of the building as contributing to a registered historic district is not sufficient. A registered historic district is any district listed in the National Register.

Charitable contribution deduction for donation of a qualified conservation contribution.

No deduction is available unless the National Register building or the registered historic district building is a certified historic structure. Most qualified conservation contribution donations claimed are in the form of a qualified real property interest that is a perpetual easement or other restriction (“easement”).

National Register building.

You can claim a deduction for the donation of an easement on all or part of the interior or exterior of a National Register building. You must include with your return:

1. Form 8283, completed as specified in its instructions;

2. A signed Qualified Appraisal, performed by a Qualified appraiser; and

3. The National Park Service project number (NPS #), if applicable. See the Instructions for Form 8283 for more information.

Registered historic district building.

You can claim a deduction for the donation of an easement on all or part of the interior of a registered historic district building. You cannot claim a deduction for the donation of an easement on the exterior of the building unless the restriction meets all of the following conditions:

1. The restriction must preserve the entire exterior of the building (including its front, sides, rear, and height) and must prohibit any change to the exterior of the building that is inconsistent with its historical character;

2. You and the organization receiving the contribution must enter into a written agreement certifying, under penalty of perjury, that the organization:

   1. Is a qualified organization with a purpose of environmental protection, land conservation, open space preservation, or historic preservation; and

   2. Has the resources to manage and enforce the restriction and a commitment to do so; and

3. You must include with your return:

   1. Form 8283, completed as specified in the Instructions for Form 8283;

   2. A signed Qualified Appraisal, performed by a Qualified appraiser;

   3. Photographs of the building’s entire exterior;

   4. A description of all restrictions on development of the building, such as zoning laws and restrictive covenants; and

   5. The National Park Service project number (NPS #), if applicable. See the Instructions for Form 8283 for more information.

If the claimed donation exceeds $10,000, you must include a $500 filing fee and a Form 8283-V, Payment Voucher for Filing Fee Under Section 170(f)(13). If you choose to pay this fee electronically, you do not need to send in Form 8283-V. Go to IRS.gov/Payments to see all of your payment options. See the instructions for Form 8283-V for more information. Your deduction will generally be disallowed if you fail to comply with this requirement.

Rehabilitation credit.

If you claim a rehabilitation credit on a National Register building or registered historic district building for any of the 5 years before the year of the qualified conservation contribution donation, your charitable contribution deduction is reduced. For more information, see Form 3468, Investment Credit (and its instructions), and section 170(f)(14).

For more information on how an NPS # applies to a certified historic structure, see Easements on certified historic structures, in the Instructions for Form 8283.

Qualified real property interest.

This is any of the following interests in real property.

1. Your entire interest in real estate other than a mineral interest (subsurface oil, gas, or other minerals, and the right of access to these minerals).

2. A remainder interest.

3. A restriction (granted in perpetuity) on the use that may be made of the real property, also commonly known as an easement, a restrictive covenant, an equitable servitude, or a perpetual conservation restriction, depending upon terminology applicable where the real property is located. See Regulations section 1.170A-14(b)(2) for further information.

Valuation.

A qualified real property interest described in (1) above consists of the following.

• Your entire interest in real property with you retaining a qualified mineral interest, or your entire interest in the real property when someone else owns the qualified mineral interest; and the probability of surface mining occurring is so remote as to be negligible. A qualified mineral interest gives you the right to access subsurface oil, gas, or other minerals. You determine the FMV of the real property absent the qualified mineral interest in the same manner that you determine the FMV of real estate. See Real Estate, earlier.

• A remainder interest in real property.

• A conservation restriction (granted in perpetuity) on the use which may be made of real property.

The value of the charitable contribution of a perpetual conservation restriction (conservation easement) is the FMV of the easement at the time of the contribution. In determining the FMV of a conservation easement, if there is a substantial record of arm’s-length sales of conservation easements on other properties that are the same as or very similar to the donated conservation easement, you must take into account the selling price of these easements. If there are no comparable sales, the FMV of the conservation easement is generally determined indirectly as the difference between the FMVs of the property before and after the grant of the conservation easement. The FMV of the property before the grant of the conservation easement must take into account not only the current use of the property but also an objective assessment of how immediate or remote the likelihood is that the property, without the easement, would be developed. In determining whether the property could be developed, you must also consider any zoning, conservation, or historical preservation laws that would already restrict the property’s potential highest and best use.

Finally, if a potential highest and best use is being considered that would require a change in zoning or other restrictions on the property, you must address whether it is reasonably probable that such a change would be permitted. Granting a conservation easement may increase, rather than reduce, the value of property, and in such a situation no deduction would be allowed.

Example.

You own 10 acres of land. Similar land in the area has an FMV of $2,000 an acre. However, land in the general area that is restricted solely to farm use has an FMV of $1,500 an acre. Your county wants to preserve open space and prevent further development in your area.

You grant to the county an enforceable open space easement in perpetuity on 8 of the 10 acres, restricting its use to farmland. The value of this easement is $4,000, determined as follows.

If you later transfer in fee your remaining interest in the 8 acres to another qualified organization, the FMV of your remaining interest is the FMV of the 8 acres reduced by the FMV of the easement granted to the first organization.

Disallowance of deductions for certain conservation contributions by partnerships or S corporations.

Subject to three exceptions, if you are an ultimate member of a partnership or an S corporation and the amount of the partnership’s or S corporation’s qualified conservation contribution exceeds 2.5 times the sum of each ultimate member’s relevant basis, the contribution is not treated as a qualified conservation contribution and no one may claim a deduction for the contribution (section 170(h)(7) disallowance rule). Thus, your charitable conservation contribution deduction is disallowed.

The term “ultimate member” means, with respect to any partnership or S corporation, any partner (that is not itself a partnership or S corporation) or S corporation shareholder that receives a distributive share or pro rata share, directly or indirectly (through one or more upper-tier partnerships or upper-tier S corporations), of a qualified conservation contribution.

Relevant basis is, with respect to any ultimate member, the portion of the ultimate member’s modified basis that is allocable to the portion of the real property with respect to which the qualified conservation contribution is made.

An upper-tier partnership or upper-tier S corporation is a partnership or S corporation that does not itself make the contribution but instead receives an allocated portion of a qualified conservation contribution from another partnership. The term “allocated portion” simply means a distributive share of a qualified conservation contribution made by a lower-tier partnership.

If the amount of a contributing partnership’s or contributing S corporation’s qualified conservation contribution exceeds 2.5 times the sum of each ultimate member’s relevant basis, the contribution is not treated as a qualified conservation contribution with respect to the contributing partnership or contributing S corporation, any upper-tier partnership or upper-tier S corporation, or any ultimate member. No one may claim a deduction for the contribution. With respect to a contributing partnership or contributing S corporation, the amount of the contribution is generally the amount claimed on the return of the contributing partnership or contributing S corporation.

If the amount of a contributing partnership’s or contributing S corporation’s qualified conservation contribution equals or is less than 2.5 times the sum of each ultimate member’s relevant basis, then any upper-tier partnership or upper-tier S corporation must determine whether the section 170(h)(7) disallowance rule applies to its allocated portion of the qualified conservation contribution.

The contributing partnership or contributing S corporation must determine each ultimate member’s relevant basis. That determination will require information from any upper-tier partnership or upper-tier S corporation and may also require information from ultimate members.

See Instructions for Form 8283 and Pub. 526 and Regulations section 1.170A-14(j) through (n) for more details on the section 170(h)(7) disallowance rule, including guidance on the computation of modified basis and relevant basis, application of the section 170(h)(7) disallowance rule in tiered structures, and the three exceptions to the section 170(h)(7) disallowance rule.

More information.

For more information about qualified conservation contributions, see Instructions for Form 8283 and Pub. 526.

Using the guidance

Keep the documents that establish the dates, amounts, and circumstances described above. References to other chapters, forms, worksheets, or earlier and later sections refer to the linked IRS publication. Check the full publication and its updates before relying on a rule for a different tax year or a situation not addressed here.

Sources and further reading

• Publication 561 (12/2025), Determining the Value of Donated Property: Valuation of Various Kinds of Property — Partial Interest in Property Not in Trust — Qualified Conservation Contribution — Internal Revenue Service; 2025 edition.

The cited U.S. government text is in the public domain. Source accessed October 28, 2026. Fynoptic has organized this material for educational use and is independent of, and not endorsed by, the IRS.