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
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
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
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
1/26/2021
/ Community Development ,
Coronavirus/COVID-19 ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Pass-Through Entities ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Relief Measures ,
Safe Harbors
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
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
6/17/2020
/ Capital Assets ,
Capital Gains ,
Coronavirus/COVID-19 ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
New Guidance ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Safe Harbors
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
6/10/2020
/ Community Development ,
Coronavirus/COVID-19 ,
Economic Development ,
Investment Funds ,
IRS ,
Low Income Housing ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Relief Measures ,
Safe Harbors
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
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 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
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
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
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
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
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
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
4/25/2019
/ Anti-Abuse Rule ,
Investors ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Transactions ,
S-Corporation ,
Safe Harbors ,
Tangible Property ,
U.S. Treasury
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
10/29/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Low-Income Issues ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
Tax Planning ,
U.S. Treasury
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
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
6/14/2018
/ Department of Revenue ,
Foreign Corporations ,
Foreign Derived Intangible Income (FDII) ,
GILTI tax ,
Governor Baker ,
Out-of-State Companies ,
Physical Presence Test ,
Quill ,
Sales & Use Tax ,
SCOTUS ,
South Dakota v. Wayfair ,
Tax Cuts and Jobs Act ,
Tax Reform
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
4/18/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Low Income Housing ,
Low-Income Issues ,
Opportunity Zones ,
Public Finance ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Reform
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