To amend the Internal Revenue Code of 1986 to encourage contributions by individuals of capital gain real property for conservation purposes, to encourage qualified conservation contributions, and to modify the rules governing the estate tax exclusion for land subject to a qualified conservation easement.

Amends the Internal Revenue Code to exclude contributions of any qualified conservation contribution or capital gain real property made for conservation purposes from the application of the special limitation on contributions of capital gain property and from the application of the five-year carryover limitation. Repeals specified property location restrictions on the estate tax exclusion for property subject to a qualified conservation easement.