CERI Act of 2026
Creates a settlement process for syndicated conservation-easement tax disputes and changes appraisal and easement rules.
In the House Ways and Means Committee since Sept. 21, 2026, 14 days after it was introduced. Most bills never leave committee.
- INTRODUCEDINTROSEP 21, 2026
- COMMITTEECOMM.IN COMMITTEE
- HOUSEHOUSE—
- SENATESENATE—
- LAWLAW—
What the bill would do, and why it matters
A conservation easement lets a landowner restrict how land can be used while seeking a tax deduction for donating those restrictions. The bill would create a settlement process for certain disputes over syndicated conservation easement deductions. It would also limit some tax assessments and penalties, change appraisal and valuation rules, and revise how certain easement terms are treated.
- INTRODUCED ONLY This bill has been introduced and possibly referred to a committee, but it has not passed any vote. Most introduced bills never become law — they die in committee without a hearing.
- DATA NOTE No Congressional Research Service summary was available.
- Creates a settlement program
The Treasury Secretary would establish a program to resolve disputes over covered syndicated conservation easement transactions. While the program is being set up, the Secretary could not start new disputes over those transactions, the time limit for disputes would be paused, and related court cases could be stayed.
- Limits taxes and penalties in disputes
For a covered transaction involving a qualified easement, the Secretary could assess a tax deficiency or penalty only in specified cases, including a materially impaired conservation purpose, a missing qualified appraisal, knowing fraud, or a gross valuation misstatement. For certain other easements whose conservation purposes are substantially preserved, the amount of a deficiency, penalty, or interest would be reduced by at least 80 percent; the bill also bars penalties under specified tax-code sections.
- Changes appraisal and valuation rules
A taxpayer’s qualified appraisal would be presumed accurate, and the Secretary would have to rebut it with clear and convincing evidence and a qualified appraisal containing specified details. In valuing property subject to a qualified conservation contribution, the bill would require consideration of certain potential uses, including mineral extraction and other development of mineral rights, when they meet stated standards.
- Provides relief for past dispositions
For covered transactions already resolved before enactment, the Secretary would pay taxpayers the amount by which their prior payment exceeds what would be due under the bill’s settlement rules. Taxpayers who filed Form 8886 would receive specified protections, including a presumption of good faith and limits on using the filing as evidence of fraud.
- Changes treatment of easement improvements
An agreement about how post-donation improvements are counted when calculating proceeds from extinguishing an easement would not, by itself, mean the conservation purpose failed to be protected in perpetuity. This change would apply to transactions entered into after December 31, 2009.
- Requires reports on implementation
The Treasury Secretary would report on the program, settlements, amounts not imposed, refusals to offer settlement terms, and payments made. The National Taxpayer Advocate would review each report and submit comments, findings, and recommendations.
The bill addresses disputes over tax deductions for syndicated conservation easement transactions. Its rules would change how those disputes are settled and how the IRS can challenge appraisals, with potential consequences for taxpayers’ tax bills and the government’s ability to assess taxes and penalties.
The bill would also change how certain post-donation improvements and possible property uses factor into conservation easement tax rules. Its required reports would give Congress information about settlements, payments, and the program’s implementation.
Written from the bill text.
The path it took, step by step
- IntroducedSEP 21, 2026HOUSESEP 21, 2026By Rep. BergmanReferred to Ways and Means
- SAME DAYNOWHouse committeeSEP 21, 2026WAYS & MEANS NOWSEP 21, 2026In committee for 14 daysNo hearing yet
- 14 DAYS SO FARPassed the House—HOUSE FLOOR—Not scheduled
- Senate committee—SENATE—
- Passed the Senate—SENATE FLOOR—Not scheduled
- Resolve differencesONLY IF NEEDEDBOTH CHAMBERSONLY IF NEEDEDSkipped if the other chamber passes the same text
- Signed into law—PRESIDENT—10 days to sign or veto
- SEP 212026SEP 21, 2026REFERREDHOUSEReferred to the House Committee on Ways and Means.
- SEP 212026SEP 21, 2026INTRODUCEDHOUSEIntroduced in House
At day 14, this bill is already older than 3% of the laws passed this Congress were when they were signed.
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