As a practitioner who regularly advises clients on qualified opportunity zone (OZ) matters, I have spent the bulk of the past three years discussing ground lease structures. Developer clients initially cringed at the notion,...more
The IRS recently issued Notice 2021-10, giving opportunity zone (OZ) investors, qualified opportunity funds (QOFs) and qualified opportunity zone businesses (OZBs) further extensions of time under various OZ rules. This...more
The U.S. Department of Treasury and the Internal Revenue Service recently issued final regulations (“the Final Regulations”) regarding certain aspects of so-called carried interest under Section 1061 of the Internal Revenue...more
2/9/2021
/ Bona Fide Purchaser ,
Capital Gains ,
Carried Interest ,
Final Rules ,
Holding Periods ,
Internal Revenue Code (IRC) ,
IRS ,
Partnerships ,
REIT ,
Related Parties ,
Tax Cuts and Jobs Act ,
U.S. Treasury
In Notice 2020-39, which was released on Thursday, June 4, 2020, the IRS provided critical relief to qualified opportunity zone (OZ) investors, qualified opportunity funds (QOF) and OZ businesses due to the COVID-19...more
The IRS has released 26 CFR Part 1, resolving questions regarding the five-year period to claim rehabilitation credits for qualified rehabilitation buildings (QRBs). Prior to the proposed regulation, practitioners were...more
In a series of related actions by the IRS designed to provide relief for taxpayers affected by the COVID-19 pandemic, the IRS, under its Code Section 7508A authority, issued Notice 2020-23 (the “Notice”). The Notice...more
The April 15 deadline for filing tax returns will be postponed until July 15, after comments from Treasury Secretary Steven Mnuchin and Notice 2020-18 posted March 20 by the IRS. This news follows Secretary Mnuchin’s...more
On April 17, 2019, the U.S. Department of Treasury and the Internal Revenue Service released their highly anticipated second tranche of qualified opportunity zone (“OZ”) proposed regulations.
This second set of proposed...more
4/23/2019
/ Capital Gains ,
Community Development ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Safe Harbors ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
U.S. Treasury
On Friday, October 19, 2018, the U.S. Treasury Department issued its first tranche of qualified opportunity zone (“OZ”) proposed regulations.
Simultaneously, the IRS released Revenue Ruling 2018-29, which addresses the...more
10/25/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Internal Revenue Code (IRC) ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
U.S. Treasury
Today, October 19, 2018, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations on the qualified opportunity zone (“OZ”) tax incentive. In addition, the IRS issued Revenue Ruling...more
On Wednesday, October 17, 2018, the Office of Information and Regulatory Affairs of the Office of Management and Budget completed its review of the proposed qualified opportunity zone (“OZ”) regulations and sent them back to...more
Today, it was announced that the proposed regulations for the qualified opportunity zone tax program (the “Program”) are being reviewed by the Office of Information and Regulatory Affairs (the “OIRA”) of the Office of...more
On July 21, 2016, the IRS issued long-awaited regulations under Section 50 of the Internal Revenue Code (the “Code”) clarifying the manner in which “Section 50(d) Income” is to be recognized in lease pass-through investment...more
7/29/2016
/ Energy Sector ,
Energy Tax Incentives ,
Historical Rehabilitation ,
Income Taxes ,
Investment Property ,
Investment Tax Credits ,
IRS ,
Land Developers ,
Lessee ,
Partnerships ,
S-Corporation ,
Tax Credits
Tax practitioners often face this issue: client is a limited liability company taxed as a partnership for federal income tax purposes (“LLC”), and it wants to issue equity to a current employee (“Individual”) without...more
The Internal Revenue Service (“IRS”) released proposed regulations changing the analysis of whether a partner bears the economic risk of loss for a partnership liability under IRC Section 752. Also, the proposed regulations...more
On January 9, 2014, the Internal Revenue Service (“IRS”) issued a revised version of previously released Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit...more
The Internal Revenue Service (“IRS”) recently issued guidance in Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit partnerships under IRC Sec. 704(b). The...more