Guidance in Proposed Regulations Expected to Jumpstart the Benefits of Qualified Opportunity Zone Investing

by McDermott Will & Emery
Contact

McDermott Will & Emery

In Depth

For many years the US tax code has enabled income tax deferral in certain situations. For the ordinary taxpayer, tax deferral opportunities include contributions made to employer-sponsored 401(k) and other qualified retirement plans; for investors, tax deferral possibilities are available via IRC § 1031 exchanges of certain types of appreciated property. Income tax deferral provisions are often used by the government to encourage taxpayer behavior. Rarely does the government offer tax elimination as an additional inducement. On December 22, 2017, the Tax Cuts and Jobs Act of 2017 (the TCJA) did just that, introducing IRC § 1400Z (Opportunity Zone Provisions) which serves as an incentive for taxpayer investment in low-income neighborhoods and combines the benefits of both tax deferral and tax elimination. On October 19, 2018, the US Treasury released highly anticipated proposed regulations (the Proposed Regulations) and Revenue Ruling 2018-29, which addresses certain issues associated with acquisitions of real property located in qualified opportunity zones.

Under the Opportunity Zone Provisions taxpayers investing capital gains in a “qualified opportunity fund” (QOF) within 180 days of realization receive three benefits; (1) tax deferral on the initial capital gain invested in the QOF, (2) potential basis step-up in the initial capital gain invested, and (3) tax elimination on the QOF investment appreciation.

Tax on the initial capital gain is deferred until the earlier of (1) the date that the QOF investment is sold, or (2) December 31, 2026. At the conclusion of the deferral, gain will be taxed on the lesser of (1) the amount of the initial capital gain invested, over the taxpayer’s basis in the initial capital gain, or (2) the now fair market value of the initial capital gain investment, over the taxpayer’s basis. The taxpayer’s basis in the initial capital gain is zero but, if the taxpayer holds the QOF investment for at least five years at the time of the deferral conclusion, the taxpayer’s basis is increased by 10 percent of the initial capital gain. If the taxpayer had held the QOF investment for at least seven years at the time of the deferral conclusion, the basis is increased by an additional 5 percent of the initial capital gain. Any appreciation in the QOF investment is eliminated provided the investment is held for 10 years. As a note, because the deferred gain will be taxed by December 31, 2026 (at latest) and because the deferred gain must be held at least seven years in order to obtain the maximum 15 percent step-up in basis, investment in a QOF should be made on or before December 31, 2019, to achieve the maximum benefit.   

To receive these benefits, the QOF must be a corporation or partnership organized for the purpose of investing in “qualified opportunity zone property” (QOZP) and at least 90 percent of the assets of which are such property. The Proposed Regulations provide clarity on two important rules as to when cash can be treated as QOZP. Specifically, the Proposed Regulations provide that cash held as working capital will be counted as QOZP and that cash from the proceeds of selling QOZP will qualify so long as such cash is reinvested within a reasonable period of time in other QOZP. To determine whether a QOF holds 90 percent of its assets as QOZP, the assets are valued based on valuations used in audited financial statements and if the company does not utilize audited financials the value of property is equal to its initial cost basis. An investment in a qualified opportunity zone stock and qualified opportunity zone partnership interest is treated in its entirety as an investment in QOZP. A QOF failing to meet the 90 percent asset percentage test will be required to pay a penalty for each month it fails the test. 

A QOZP is defined as property that is “qualified opportunity zone stock,” a “qualified opportunity zone partnership interest,” or “qualified opportunity zone business property.”

 “Qualified opportunity zone stock” and “qualified opportunity zone partnership interest” is stock or an interest in a US corporation or partnership, respectively. The stock or interest must be acquired by the QOF after December 31, 2017, at original issue and solely in exchange for cash. At the time the stock or interest is issued, the entity must be a “qualified opportunity zone business” (QOZB) (or, in the case of a new entity, organized for purposes of being a QOZB). The entity must remain a QOZB for substantially all of the time the QOF holds the stock or interest.

A “qualified opportunity zone business” (QOZB) is a trade or business in which substantially all of the tangible property owned or leased by the taxpayer is “qualified opportunity zone business property” (QOZBP). The Proposed Regulations provide a safe harbor clarifying that if 70 percent or more of the tangible property is QOZBP, the entity will own an adequate amount of tangible property to meet this requirement. At least 50 percent of the total QOZB’s gross income must be derived from the active conduct of such business, a “substantial portion” of the intangible property of the QOF must be used in the QOZB, and the average of the aggregate unadjusted bases of the QOZBP attributable to “nonqualified financial property” must be less than 5 percent.

A QOZBP owned by a QOZB may not be used to provide, including the provisioning of land, for any private or commercial golf course, country club, massage parlor, hot tub facility, suntan facility, racetrack or other facility used for gambling, or any store the principal business of which is the sale of alcoholic beverages for consumption off the premises.

A QOZBP means tangible property used in a trade or business of the QOF if (1) the property was purchased by the QOF after December 31, 2017, (2) the original use of the property in a “qualified opportunity zone” starts with the QOF, or the QOF substantially improves the property, and (3) substantially all of the use of the property was in a “qualified opportunity zone” during substantially all of the time the QOF holds the property. Future regulations will be issued to clarify what “substantially all” of the use of the property and “substantially all” of the time holding the property means. “Qualified opportunity zone business property” will be treated as substantially improved by a QOF only if during any 30-month period beginning after the date of the property’s acquisition its basis is increased by an amount exceeding its initial cost basis. In the case of real property, the Proposed Regulations and Rev. Rul. 2018-29 make an important clarification. Even though land can never be put to first use by a taxpayer, the guidance from Treasury clarifies that the price paid for land is excluded for purposes of determining whether substantial improvement occurs. For example, if a QOF acquires a parcel of real estate, which includes land with a value of $60,000 and a building with a value of $40,000, to substantially improve this property would require that the QOF incur $40,000 of improvement to the building. 

Under IRC § 1400Z-1 a “qualified opportunity zone” (QOZ) is a low-income community that is designated as a qualified opportunity zone by the state in which it is located and certified by the US Treasury.

In sum, a QOF can invest its funds in a QOZBP through a QOZB that is a corporation or partnership, or it can invest directly in to a QOZBP. One advantage of investing directly in to a QOZBP is the ability to engage in the business listed above (e.g., golf course, country club, massage parlor, hot tub facility, suntan facility, etc.) as opposed to investing in a QOZBP owned by QOZB and which is not permitted to engage in these businesses.  Other advantages of a QOF investing directly in QOZBP include the QOF’s ability to hold up to 10 percent of the QOF’s assets in cash (versus the 5 percent—plus working capital—threshold for QOZB investments) and the absence of a minimum percentage of gross income that the QOF must derive from the QOZBP (versus the requirement that a minimum of 50 percent of a QOF’s gross income be derived from QOZB investments).

On the other hand, the advantages of a QOF investing in QOZB include the absence of a minimum percentage of QOF assets that must be invested in tangible property (versus the minimum 90 percent requirement for QOZBP investments). Thus, a QOZB can be comprised entirely of intellectual property. For example, a tech startup company located in a qualified opportunity zone could issue qualified opportunity zone stock even if the majority of its assets is comprised of intellectual property. Moreover, to the extent the QOZB owns tangible property only 70 percent of such property need be QOZBP. This flexibility on asset composition puts the QOZB investment at an advantage in many cases.  The non-taxation of gain provisions under the Opportunity Zone Provisions differ from general IRC non-taxation of gain provisions (e.g., IRC § 1031) in that, generally, under the other IRC provisions deferral of gain is only permitted if the taxpayer reinvests the entirety of the sales proceeds in the new property—which includes both the portion representing basis and the portion representing gain. Taxpayers may choose to defer all or a portion of a capital gain. In contrast, the Opportunity Zone Provisions require only that the taxpayer invest the gain from a sale to receive the deferral treatment. Second, as noted above, IRC § 1400Z does not only defer the initial capital gain from tax and potentially reduce the amount of such tax, but also enables the QOF investment appreciation to never be taxed—assuming that the investment is held for 10 years. The Proposed Regulations allow an investor to pledge his or her interest in a QOF as collateral on a loan. Thus, the investor can receive a significant amount of cash from the capital gain event, while still otherwise receiving the benefits of the Opportunity Zone Provisions. Moreover, an investor can continue to defer the capital gain even if he or she were to sell the interest in the QOF within the seven year period, so long as the initial investment is entirely disposed of by the investor and is reinvested within 180 days in a replacement QOF.

How It Works – by the Numbers

As an example, assume an investor invests $1,000,000 of capital gain in a QOF in 2018 (QOF Investment). The deferred gain will be taxed at the earlier of (1) the date on which the taxpayer sells the QOF Investment, or (2) December 31, 2026. The amount taxed will be $1,000,000, reduced by the investor’s basis in the QOF Investment. If on the date that the QOF Investment is sold the QOF Investment is worth less than $1,000,000, then the QOF Investment is taxed at its fair market value on the date on which it is sold, reduced by the investor’s basis in the QOF Investment.

The investor’s basis in the QOF Investment is initially zero, but if the investor holds the QOF Investment for at least five years (e.g., until 2023), the investor’s basis in the QOF Investment becomes $100,000 (10 percent of $1,000,000); if the investor holds the QOF Investment for at least seven years (e.g., until 2025), the investor’s basis in the QOF Investment becomes $150,000 (15 percent of $1,000,000). After the $1,000,000 is taxed, the taxpayer’s new basis in the QOF Investment becomes $1,000,000. Therefore, if the investor holds the QOF Investment for nine years (e.g., until 2027), the amount taxed will be any appreciation in the investment over the $1,000,000 of new basis. If the investor holds the QOF Investment for at least 10 years (e.g., until 2028), the investor’s basis in the QOF Investment is increased to the fair market value of the QSF Investment on the date on which it is sold, resulting in none of the investment appreciation being taxed (i.e. any increase in the investment over $1,000,000 is never taxed).

The benefits to the investor in this example are (1) tax deferral of the $1,000,000 of initial capital gain invested in the QOF until the earlier of the date that the QSF investment is sold, or December 31, 2026; (2) decrease of the $1,000,000 of initial capital gain ultimately taxed to $900,000 (90 percent) or $850,000 (85 percent), depending on whether the investment is held for five or seven years, and most noteworthy (3) tax avoidance on any appreciation that the $1,000,000 of initial capital gain invested in the QOF generates, if the QOF Investment is held for 10 years.

Conclusion

The Opportunity Zone Provisions provide rare tax benefits for many investors. While the recently released Proposed Regulations answer many questions, additional regulations and guidance from the IRS and the US Treasury is expected before year-end.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© McDermott Will & Emery | Attorney Advertising

Written by:

McDermott Will & Emery
Contact
more
less

McDermott Will & Emery on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.