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Proposed Bipartisan Amendments to the Opportunity Zone Statute Could Have a Significant Effect on Current and Potential Investors

Late last week, a bipartisan group of U.S. Senators and U.S. Representatives introduced an expansive bicameral bill, titled the Opportunity Zones Transparency, Extension, and Improvement Act (the “OZ Bill”). This proposed...more

2020 Census Results Have No Impact on Boundaries of Opportunity Zones

The IRS has issued Announcement 2021-10 (the “Announcement”) in response to public questions regarding the potential effect the 2020 Census results may have on the boundaries of previously designated Opportunity Zones. ...more

Latest Proposed Regulations Provide Needed Guidance on the Working Capital Safe Harbor

Nestled within the new proposed regulations issued by the IRS on April 12 (the "Proposed Regulations") that mainly address foreign investors is needed relief for current Opportunity Zone projects....more

Internal Revenue Service Provides Additional COVID-19 Related Relief for Opportunity Zones Investors

On January 19, 2021, the Internal Revenue Service (“IRS”) issued Notice 2021-10 (the “Notice”), which provides relief for Opportunity Fund investors from certain deadlines and testing requirements. The relief provided by the...more

The House of Representatives Tries Again, Calling for Economic Relief for Renewables

Recently, several members of the House of Representatives (the “House”) sent a letter requesting economic relief for the renewable energy industry, which has been severely hit by the COVID-19 crisis. Prior to the pandemic,...more

Opportunity Zone Best Practices – Not All Extensions are Automatic

The IRS recently issued additional Opportunity Zone-related guidance, Notice 2020-39, that grants extension relief with respect to five specific time-sensitive actions. Among other things, Notice 2020-39 (i) allows certain...more

IRS Provides Relief to Opportunity Funds and OZ Investors

As part of its continuing response to the COVID-19 pandemic, on June 4, 2020, the Internal Revenue Service issued Notice 2020–39 (the “Notice”). The Notice provides welcome relief to Qualified Opportunity Funds (“QOFs”) and...more

OZone Record-Keeping: How to Be Prepared

The Sullivan Opportunity Zone Practice Group has previously written a client alert promoting the benefits of detailed record-keeping for taxpayers operating in the OZone world. There are certain specific records that are...more

A Breath of Fresh Air During the Pandemic: Treasury Plans to Extend PTC and ITC Deadlines for Renewables

The U.S. Department of the Treasury ("Treasury") plans to adjust the current safe-harbor guidelines for the federal production tax credit ("PTC") and investment tax credit ("ITC"), providing some certainty and predictability...more

The Best Practice Remains "File on Time"

The Sullivan Opportunity Zone Practice Group has issued multiple advisories and alerts which stand for the proposition that "words matter." To that mantra, we add "deadlines matter, too." In a recent Private Letter Ruling...more

Being “IN BOUNDS” is Important Even When You Aren’t Playing Golf - (or R-E-L-I-E-F is not spelled A-B-U-S-E)

The Coronavirus Aid, Relief, and Economic Security Act or the "CARES Act" and related federal stimulus legislation were collectively aimed at providing financial relief to individuals and businesses adversely affected by the...more

Where We Go From Here: Using the OZ Act to Move Beyond Covid-19

How will the United States recover from the COVID-19 pandemic? At least part of the answer may be by making a few critically important tweaks to the Opportunity Zone tax incentives contained in Code Section 1400Z-2 (the “OZ...more

Opportunity Zone Best Practices During COVID-19

As we all re-examine business practices in the uncharted waters of COVID-19, the Sullivan Opportunity Zone Practice Group will be publishing concise reminders of best practices. Guidance abounds, including our own,...more

20 Ozone Things to Know for 2020 (Part 1)

Two months have elapsed since Treasury and IRS issued the Final Regulations on Opportunity Zones. The effective date is March 13, 2020. During these two months, the Sullivan Ozone Practice Group has hosted gatherings for our...more

Massachusetts Department of Revenue Issues Draft Technical Information Release Addressing Opportunity Zones

On May 9, 2019, the Massachusetts Department of Revenue issued for practitioner comment a working draft Technical Information Release ("TIR") addressing the Massachusetts corporate excise and personal income tax ramifications...more

Second Round of Treasury Guidance: Key Provisions

The long-awaited second round of Opportunity Zone-related Proposed Regulations were issued Wednesday, April 17, 2019. It is clear that Treasury’s goals, in its second round of guidance, were to: 1. Provide clarity and/or...more

Structuring Opportunity Zone Funds

The Opportunity Zones Program created by the U.S. Tax Cut and Jobs Act of 2017 (the "OZone Program") and the first wave of proposed regulations issued by the Treasury Department on October 19, 2018 (the "Regulations") have...more

Treasury Department Releases Investor-Friendly Proposed Opportunity Zones Regulations

On October 19, 2018, the Treasury Department issued highly-anticipated proposed regulations related to the U.S. Tax Cut and Jobs Act of 2017's Opportunity Zones Program (the "Proposed Regulations"). Taxpayers and investors...more

Governor Baker Proposes Tax Changes to Address Federal Reform, Wayfair Case

In a supplemental appropriations bill for FY 2018, Governor Charlie Baker has proposed amendments to Massachusetts tax law that would deal with the two "hottest" issues on the state and local tax front nationally in the...more

Legislation Creating Opportunity Zones Offers Significant Tax Benefits — An Overview

Recent federal tax legislation introduced "Opportunity Zones," a new community reinvestment tool designed to use tax incentives to drive long-term investment to rural and low-income urban communities throughout the nation....more

LIHTC Bulletin

On Friday, March 23, 2018, the President signed a $1.3 trillion Omnibus Spending bill that had been passed by Congress. Two (2) provisions of the bill are important to those involved in the Low-Income Housing Tax Credit...more

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