The Treasury Department released final Opportunity Zone regulations on December 19, which combine and clarify the prior two sets of guidance, as well as an FAQ summary. The new guidance provides greater flexibility in satisfying various requirements of the qualified opportunity fund program, and addresses several previously unresolved issues. The final regulations address the following, among other things: 

• Types of gain and timing for eligible investment
• Gain exclusion timing and effect of inclusion events
• Debt-financed distributions and avoidance of disguised sale treatment
• New investments and original use of property
• Leasing exemptions and presumptions
• Working capital safe harbor extensions
• Use of tangible and intangible property
• Substantial improvement tests