Seyfarth Synopsis: On April 12, 2021, the Department of Treasury (“Treasury”) published proposed Treasury regulations (the “Proposed Regulations”) that (1) permit qualified opportunity zone businesses (“QOZBs”) to revise or...more
Seyfarth Synopsis: On October 19, 2018, the U.S. Department of the Treasury released long-anticipated proposed regulations (the “Proposed Regulations”) relating to investments in Qualified Opportunity Zones (“QOZs”)....more
10/29/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more
11/7/2016
/ Cross-Border Transactions ,
Debt Financing ,
Debt-Equity ,
Disguised Sales ,
Disregarded Entities ,
Foreign Subsidiaries ,
Inversion ,
IRS ,
Multinationals ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Reclassification Rules ,
Recordkeeping Requirements ,
REIT ,
RICs ,
S-Corporation ,
Subsidiaries ,
U.S. Treasury
Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more