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Capital Gains Internal Revenue Service Investment Funds

DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

DLA Piper on

The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

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If you acquired or built a senior living facility that is located in an opportunity zone, or are considering doing so, a recent bipartisan bill introduced in Congress proposes making changes to the opportunity zone rules. ...more

Obermayer Rebmann Maxwell & Hippel LLP

Call to Increase Transparency Of Opportunity Zone Program

From the date of its inception, the Opportunity Zone Program has been criticized for its lack of transparency and reporting requirements. The original version of the law included reporting requirements, but some of those...more

McDermott Will & Emery

The Nonqualified Financial Property Limitation

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Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

How to Invest in a QOF

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Williams Mullen

Ding Dong, the OZ Ground Lease (May Be) Dead!

Williams Mullen on

As a practitioner who regularly advises clients on qualified opportunity zone (OZ) matters, I have spent the bulk of the past three years discussing ground lease structures. Developer clients initially cringed at the notion,...more

Stinson LLP

IRS Extends Relief for Qualified Opportunity Funds

Stinson LLP on

On January 19, 2021, the IRS issued Notice 2021-10, further extending relief for qualified opportunity funds (QOF) and their investors due to the COVID-19 pandemic. The IRS had provided relief last year in Notice 2020-39, and...more

Latham & Watkins LLP

Final Carried Interest Regulations: Key Takeaways for Private Fund Sponsors

Latham & Watkins LLP on

While the final regulations simplify key exceptions and contain favorable changes, ambiguity continues for investment fund managers. On January 7, 2021, the US Treasury Department and Internal Revenue Service (together,...more

Morgan Lewis

IRS Extends Previously Issued Relief to Qualified Opportunity Funds and Their Investors

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The Internal Revenue Service (IRS) issued Notice 2021-10 on January 19, which extends relief to Qualified Opportunity Funds (QOFs) and their investors as a response to continued challenges brought on by the COVID-19 pandemic....more

A&O Shearman

IRS Proposes Carried Interest Rules Recharacterizing Certain Capital Gain in Connection with Profits Interests

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On July 31, 2020, the Internal Revenue Service (IRS) published proposed regulations providing guidance under Section 1061 (the “Proposed Regulations”) of the Internal Revenue Code (the “Code”). Section 1061, which was added...more

Tonkon Torp LLP

Top Three Investor-Friendly Rules From The Newest IRS Opportunity Zone Notice

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The IRS issued Notice 2020-39 on June 5, 2020 in response to the COVID-19 pandemic, which extended several deadlines applicable to Opportunity Zone investments. •First, investors get more time to invest eligible gains into a...more

Ruder Ware

Responding to the Pandemic, IRS Loosens Opportunity Zone Requirements

Ruder Ware on

The IRS recently offered relief to Qualified Opportunity Fund investors, waiving a penalty and pushing back some investment deadlines. This new guidance comes as investment in opportunity zones slows, stymied by brisk...more

Tarter Krinsky & Drogin LLP

Internal Revenue Service Announces Relief For Qualified Opportunity Zone Investors

On June 4, 2020, the Internal Revenue Service issued Notice 2020-39, which is available here. Notice 2020-39 provides temporary relief to qualified opportunity funds (QOFs) and their investors as a result of the COVID-19...more

Ballard Spahr LLP

IRS Further Extends Qualified Opportunity Zone Deadlines

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In Notice 2020-39, the IRS extended a number of deadlines for the Qualified Opportunity Zone (QOZ) program. For a detailed explanation of the rules applicable to the QOZ program, see our discussion of the final QOZ...more

Pierce Atwood LLP

IRS Provides Relief on Opportunity Zone Deadlines

Pierce Atwood LLP on

On June 4, 2020, in response to the ongoing COVID-19 pandemic, the IRS issued Notice 2020-39 to provide relief regarding various deadlines applicable to the federal opportunity zone program....more

Lowndes

IRS Provides Much-Needed Opportunity Zone Relief

Lowndes on

On June 4, the IRS provided some much-needed relief to opportunity zone investors and qualified opportunity funds (QOFs) in response to the ongoing COVID-19 pandemic. Specifically, the IRS published Notice 2020-39, which...more

Orrick, Herrington & Sutcliffe LLP

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more

Polsinelli

Polsinelli Commentary on the Final Opportunity Zone Regulations

Polsinelli on

Treasury issued final Opportunity Zone Regulations on December 19, 2019 (“Final Regulations”).  These Final Regulations update the first two rounds of Proposed Regulations (issued on October 29, 2018 and April 17, 2019)....more

McDermott Will & Emery

Highlights from the Final Opportunity Zone Regulations

McDermott Will & Emery on

The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more

Proskauer - Tax Talks

Final Regulations on Opportunity Zones

Proskauer - Tax Talks on

On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code...more

Seyfarth Shaw LLP

Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations

Seyfarth Shaw LLP on

Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

Jackson Walker on

On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more

Lowndes

Industry News Briefs

Lowndes on

Happy New Year! Did I Miss My Chance at Opportunity Zones? Opportunity zones were introduced in 2017 as part of President Trump’s tax reform bill. Taxpayers with capital gains can receive several tax benefits if the...more

A&O Shearman

Opportunity Zones: Final Regulations Provide Additional Flexibility

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On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to...more

Ballard Spahr LLP

Treasury Releases Final Regulations On Qualified Opportunity Zone Program

Ballard Spahr LLP on

The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more

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