News & Analysis as of

Investment Funds Internal Revenue Code (IRC)

Levenfeld Pearlstein, LLC

A Tale of Two DSTs: Beware of Confusing 1031 DSTs with 453 DSTs

Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...more

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

McDermott Will & Emery

The Domestic Content Bonus Credit’s Promising New Safe Harbor

McDermott Will & Emery on

On May 16, 2024, the Internal Revenue Service (IRS) published Notice 2024-41 (Notice), which modifies Notice 2023-38 (Prior Notice) by providing a new elective safe harbor (Safe Harbor) that will allow taxpayers to use...more

Groom Law Group, Chartered

Amendment to QPAM Exemption

On April 2, 2024, the Department of Labor (“DOL” or “Department”) released an amendment (the “Amendment”) to Prohibited Transaction Exemption 84-14 (the “QPAM Exemption” or “Exemption”). The changes were proposed by DOL in...more

Seward & Kissel LLP

For Fund Managers, Tax Court Ruling Sets Limited Partners Back “As Such”

Seward & Kissel LLP on

Memorandum to our Investment Management Clients and Friends - The United States Tax Court recently issued a ruling (the “Ruling”) pertaining to the possible exclusion of a limited partner’s distributive share of income...more

Bilzin Sumberg

Proposed Regulations May Affect Taxation of Foreign Investors in REITs

Bilzin Sumberg on

On December 29, 2022 the IRS and the Treasury Department issued a notice of proposed rulemaking (REG-100442-22) (the “Proposed Regulations”) that, among other things, affects the determination when Real Estate Investment...more

McDermott Will & Emery

Inflation Reduction Act & Long-Term Capital Gain for Carried Interest

OVERVIEW OF CARRIED INTEREST RULES Section 1061 of the Code, enacted in 2017 as part of the Tax Cuts and Jobs Act, recharacterizes certain gain that would otherwise qualify as long-term capital gain with respect to...more

Verrill

DOL Proposes Amendments to QPAM Exemption

Verrill on

On July 27, 2022, the Department of Labor (DOL) proposed a set of amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” which permits an investment fund holding assets of ERISA plans and...more

Jackson Lewis P.C.

Carried Interest/Promote in 2022: Action Items for Investment, Private Equity, Real Estate Fund Managers

Jackson Lewis P.C. on

Investment, private equity, and real estate fund managers should consider becoming familiar with the complex final regulations on the preferential tax treatment of “carried interest” under Section 1061 of the Internal Revenue...more

McDermott Will & Emery

The Nonqualified Financial Property Limitation

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Butler Snow LLP

Combining the Energy Credit with New Markets Tax Credits

Butler Snow LLP on

Section 48 of the Internal Revenue Code of 1986 provides for a credit equal to a percentage of the cost of new equipment for the generation of renewable energy, including solar energy used to produce electricity or to heat or...more

Allen Matkins

Fast Facts on the Top 10 Relevant Regulatory Areas for Real Estate Fund Managers

Allen Matkins on

There are many advantages to forming a commingled real estate investment fund. These include providing a pool of capital to draw upon quickly as competitive opportunities arise and allowing an investor to build a brand as an...more

Lowndes

IRS Extends Much-Needed Opportunity Zone Relief

Lowndes on

This week, the IRS issued Notice 2021-10, which extends the June 4, 2020 relief that the IRS previously granted to opportunity zone investors and qualified opportunity funds (QOFs) in response to the ongoing COVID-19...more

Morrison & Foerster LLP

IRS Rules That Impact Investment Fund Is Not Charitable Activity

Over the last decade, impact investing has become a significant focus of many nonprofits, just as it has captured the attention of investors who care about social benefit or environmental results as much as financial results....more

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

McDermott Will & Emery on

The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

King & Spalding

IRS and Treasury Release Final Opportunity Zone Regulations

King & Spalding on

On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more

Weintraub Tobin

The Wonderful Land of OZ: An Overview of Opportunity Zones

Weintraub Tobin on

Opportunity Zones (or OZs) may be the most talked about provision of the Tax Cuts and Jobs Act of 2017.  There are many twists and turns on the yellow brick road to completing an OZ project.  This article sets forth the...more

Whitman Legal Solutions, LLC

How Struggling Orchestras are Like Qualified Opportunity Zone Funds

Symphony orchestras are important to their communities and to developing young talent, but they are struggling. Perhaps it’s no coincidence that the downtown areas of many cities also struggle to remain vital, as they...more

Troutman Pepper

Qualified Opportunity Zones: Additional Regulatory Guidance - TAX UPDATE Volume 2019, Issue 3

Troutman Pepper on

In April, the Department of the Treasury released the much-anticipated second round of Treasury Regulations under section 1400Z-2 of the Internal Revenue Code (April Regulations). This article provides certain highlights of...more

King & Spalding

Investments in Renewable and Conventional Power Projects in Qualified Opportunity Zones

King & Spalding on

The Qualified Opportunity Zone rules under Section 1400Z of the Internal Revenue Code permit certain investors to realize substantial tax benefits if they invest capital into federally-designated low-income communities known...more

Farella Braun + Martel LLP

Legal Ins and Outs of ‘Opportunity Zones’ — so Far

A new tax incentive intended to stimulate investment in low-income communities known as opportunity zones has attracted significant attention from investors, developers, and business owners since its enactment under Section...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Bracewell LLP

Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations

Bracewell LLP on

After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “Second Tranche”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act...more

Parker Poe Adams & Bernstein LLP

Second Round of Proposed Opportunity Zone Regulations Published Today in Federal Register

Investors, property owners, real estate developers, and other businesses now have much clearer guidelines for how they can obtain tax benefits under the federal Opportunity Zone program. The IRS published the long-awaited...more

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