There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception.
Internal Revenue Code Section 1231 applies to depreciable property and...more
6/28/2019
/ Capital Gains ,
Community Development ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Tax Planning
OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM -
The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...more
5/3/2019
/ Anti-Abuse Rule ,
Capital Gains ,
Corporate Entities ,
Investment Opportunities ,
Investment Property ,
IRS ,
New Guidance ,
Opportunity Zones ,
Partnerships ,
Pass-Through Entities ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Reinvestment Funds ,
Rollover Equity ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Tax-Deferred Exchanges ,
U.S. Treasury
In a very busy end of the year, the IRS provided two new bond regulations: The final public approval (TEFRA) regulations and proposed reissuance regulations....more
The proposed Tax Cuts and Jobs Act released last week would eliminate the federal tax exemption for interest earned on all private activity bonds—including 501(c)(3) bonds and exempt facility bonds—and advance refunding bonds...more
11/6/2017
/ 501(c)(3) ,
Bonds ,
Infrastructure ,
Internal Revenue Code (IRC) ,
IRS ,
LIHTC ,
Low Income Housing ,
Low-Income Issues ,
Proposed Legislation ,
Public Projects ,
State and Local Government ,
Tax Code ,
Tax Reform ,
Tax-Exempt Bonds
State and local governments and 501(c)(3) organizations have been given very flexible guidance by the IRS for longer-term private management of tax-exempt bond financed projects to facilitate general operations and major...more
8/26/2016
/ 501(c)(3) ,
Compensation ,
Construction Industry ,
Infrastructure ,
IRS ,
Management Contracts ,
Project Finance ,
Public Private Partnerships (P3s) ,
Public Projects ,
Safe Harbors ,
Service Contracts ,
Tax-Exempt Bonds
The U.S. Treasury Department and the Internal Revenue Service (IRS) held a public hearing on the definition of issue price for tax-exempt bonds on October 28, 2015. The hearing is another step in the process of changing what...more
The IRS has released guidance in three areas of interest to entities that benefit from tax-exempt bond financings, particularly hospitals and educational institutions. This guidance creates new rules related to management...more
2/3/2015
/ 501(c)(3) ,
ACOs ,
Affordable Care Act ,
Bond Financing ,
Educational Institutions ,
Exempt Organizations ,
Hospitals ,
IRS ,
Management Agreements ,
New Regulations ,
Safe Harbors ,
Tax-Exempt Bonds
The Internal Revenue Service last month published a memorandum for its exempt organizations specialists regarding the treatment of exempt organizations still awaiting their determination letters that have failed to file an...more