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Capital Gains Tax Cuts and Jobs Act Proposed Regulation

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

Jones Day

U.S. Treasury Department Releases Proposed Carried Interest Regulations

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The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more

Neal, Gerber & Eisenberg LLP

Fund Managers and Family Offices Get Some Clarity on Carried Interests with Issuance of Proposed Treasury Regulations

On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more

McDermott Will & Emery

IRS Issues Proposed Regulations Intended to Clarify Carried Interest Rules

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The Internal Revenue Service (IRS) recently issued proposed regulations under section 1061, a provision enacted as part of the Tax Cuts and Jobs Act of 2017 (TCJA) that recharacterizes certain net long-term capital gain with...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations and the Impact on Private Equity

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Treasury and the IRS released proposed regulations under Section 1061 of the Internal Revenue Code (the Code) on July 31, 2020, that require certain taxpayers to satisfy a three-year holding period, rather than a one-year...more

Troutman Pepper

Proposed Regulations Shed Light on Three-Year Holding Period Requirement for Carried Interest

Troutman Pepper on

Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more

Ballard Spahr LLP

Carried Interest – Proposed Regulations – Impact on Real Estate: The Good and the Bad

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On July 31, 2020, the IRS and Treasury released the long-awaited proposed regulations on the new carried interest rules in Section 1061 of the Internal Revenue Code (IRC) that became law as part of the Tax Cuts and Jobs Act...more

White & Case LLP

Overview of the Carried Interest Rules and the Proposed Regulations

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On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more

Dechert LLP

Proposed Carried Interest Regulations: Treasury Carries the Ball, Giving Precious Few Points to Fund Managers

Dechert LLP on

The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more

Proskauer - Tax Talks

 “Passthrough Deduction” Regulations for RICs Finalized with No Major Changes

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On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...more

McGlinchey Stafford

IRS Proposes New Like-Kind Exchange Regulations

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The 2017 Tax Cut and Jobs Act (TCJA) limited like-kind exchanges occurring after 2017 to “real property held for productive use in a trade or business or investment if such real property is exchanged for real property of a...more

Sullivan & Worcester

20 Ozone Things to Know for 2020 (Part 1)

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Two months have elapsed since Treasury and IRS issued the Final Regulations on Opportunity Zones. The effective date is March 13, 2020. During these two months, the Sullivan Ozone Practice Group has hosted gatherings for our...more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

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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

McDermott Will & Emery

Weekly IRS Roundup December 16 – 20, 2019

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

K&L Gates LLP

Opportunity Zone Final Regulations: First Impressions - Final Rules Strive for Balance of Certainty and Flexibility for OZ...

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Almost exactly two years after enactment in the Tax Cuts and Jobs Act, Treasury has released final regulations on the Opportunity Zone (“OZ”) tax incentive. ...more

Smith Debnam Narron Drake Saintsing & Myers,...

Latest Opportunity Zone Regulations Provide Needed Clarity to Investors, Fund Managers, and Businesses

On April 17, 2019, the United States Department of the Treasury (“Treasury”) issued its second round of proposed regulations related to investments in Qualified Opportunity Zones (“QOZs”) and Qualified Opportunity Funds...more

K&L Gates LLP

Opportunity Zones: Second Round of Proposed Regulations Are Helpful for Agribusiness and Forestry, but Refinements Are Needed to...

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The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for many industries, as we discussed soon after the TCJA became law. The first set of proposed regulations...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more

Miles & Stockbridge P.C.

2nd Tranche of OZ Regulations

On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more

BCLP

The Adviser: A Quarterly Update for Private Fund Advisers

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This newsletter discusses recent key guidance releases, regulatory changes, noteworthy news and certain upcoming compliance deadlines. Topics include: - 10 Things You Should Know About Opportunity Zones - ILPA...more

K&L Gates LLP

Opportunity Zones: Second Round of Proposed Regulations Are Good News For Renewables, But Refinements Are Needed

K&L Gates LLP on

The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for renewable energy and other industries, as we discussed soon after the TCJA became law. ...more

Blank Rome LLP

IRS Publishes Second Set of Opportunity Zone Proposed Regulations

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The Internal Revenue Service and the Treasury Department recently released a second tranche of proposed regulations that provide additional guidance on the tax incentives of investing in opportunity zones, including the...more

Nossaman LLP

P3 Investors: Are You In The Zone?

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Last December we told you about favorable IRS guidance letting P3 contractors and investors keep full tax deductions for interest on debt. The IRS kept a P3-friendly approach in last week’s proposed regulations on “qualified...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Second Set of Qualified Opportunity Zone Proposed Regulations Provide Clarity to Potential Investors

As discussed here in November (Why 2019 Will be the Year of Opportunity (Zones)), the Tax Cuts and Jobs Act created a tax-advantaged incentive program for investing in designated “qualified opportunity zones” throughout the...more

K&L Gates LLP

Worth the Wait: Second Round of Opportunity Zone Proposed Regulations Clears the Way for Many OZ Investments

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After a lengthy drafting and protracted review process, the Department of Treasury (“Treasury”) has released its second set of proposed regulations (the “Second Round Regs”) providing guidance on the implementation of the...more

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