Certain qualified conservation contributions
(A) In general In the case of a qualified conservation contribution to which this paragraph applies, no deduction shall be allowed under subsection (a) for such contribution unless the partnership making such contribution— (i) includes on its return for the taxable year in which the contribution is made a statement that the partnership made such a contribution, and (ii) provides such information about the contribution as the Secretary may require.
(B) Contributions to which this paragraph applies This paragraph shall apply to any qualified conservation contribution— (i) the conservation purpose of which is the preservation of any building which is a certified historic structure (as defined in subsection (h)(4)(C)), (ii) which is made by a partnership (whether directly or as a distributive share of a contribution of another partnership), and (iii) the amount of which exceeds 2.5 times the sum of each partner’s relevant basis (as defined in subsection (h)(7)) in the partnership making the contribution.
(C) Application to other pass-through entities Except as may be otherwise provided by the Secretary, the rules of this paragraph shall apply to S corporations and other pass-through entities in the same manner as such rules apply to partnerships.