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Qualified Opportunity Zone Fund Investments
Last week, U.S. Senators Shelley Moore Capito, R-West Virginia, and Mark Warner, D-Virginia, introduced S. 631, which focuses on rural historic tax credit (HTC) use and also includes transferability for small projects (those...more
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
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
With the issuance of Notice 2020-39 (the Notice), the Internal Revenue Service (IRS) has provided relief for Qualified Opportunity Zone Funds (QOFs) and for investors in QOFs. While the relief provided in the Notice does not...more
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
As part of its continuing response to the COVID-19 pandemic, on June 4, 2020, the Internal Revenue Service issued Notice 2020–39 (the “Notice”). The Notice provides welcome relief to Qualified Opportunity Funds (“QOFs”) and...more
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
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
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
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
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
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 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
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
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
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
On December 19, 2019, the Treasury Department and Internal Revenue Service (the “IRS”) released final regulations for the opportunity zone (“OZ”) program to refine and clarify certain aspects of the first two sets of proposed...more
On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more
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....more
On Thursday, December 19th, the U.S. Department of Treasury released the long-awaited final Opportunity Zone Treasury Regulations (the “Final Regulations”). The Final Regulations and explanatory materials that span 544 pages,...more
On December 22, 2017, Congress enacted the Tax Cuts and Jobs Act of 2017 (the “Tax Act”). The law created a new incentive to encourage long-term investment in the nation’s low-income areas. If a taxpayer invests eligible...more
As 2019 comes to a close, there is an important deadline approaching for opportunity zone investors. December 31, 2019 is the last day on which investors can make an investment in a qualified opportunity fund (“QOF”) and...more
In April, the Department of the Treasury released the much-anticipated second round of Treasury Regulations under section 1400Z-2 of the Internal Revenue Code (April Regulations). This article provides certain highlights of...more
1. Who Can Invest? U.S. or foreign investors and pass-through entities recognizing U.S. capital gains. 2. What Type of Capital Gain Qualifies? Long term and short term capital gains qualify. ...more
The Qualified Opportunity Zone (“QOZ”) regime introduced as part of the 2017 Tax Cuts and Jobs Act provides three significant and distinct federal income tax benefits to encourage QOZ private investment: ..A taxpayer may...more