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Qualified Opportunity Zone Fund Investments
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
Under current legislation, tax-exempt and other low cost financing solutions are not typically available for social infrastructure projects....more
The Tax Cuts and Jobs Act (“TCJA”) provided the most comprehensive update to the tax code in over two decades. Of the many changes the TCJA provided, Sections 1400Z-1 and 1400Z-2 of the IRC are of the most heavily discussed...more
The “Opportunity Zone” community development program was established by Congress in the 2017 Tax Cuts and Jobs Act to encourage long-term investments in low-income urban and rural communities nationwide. ...more
Below are questions submitted by the audience during our webinar Window of Opportunity: The IRS Issues Initial Guidance on Qualified Opportunity Zone Rules. The webinar was on November 2, 2018. Here’s the presentation from...more
The recently enacted Tax Cuts and Jobs Act provided for a new set of provisions designed to incentivize long-term investment in certain low-income areas nominated by states and designated by the Treasury Department...more
The federal Opportunity Zone (OZ) program, created in December 2017, has been a major topic of discussion for investors, businesses, and project developers alike. It seems, however, that the utilization of the OZ program has...more
The 2017 tax bill provides massive tax benefits to any taxpayer that recognizes capital gain (“Gain”) and that invests an amount equal to the Gain to acquire an interest (“Fund Interest”) in an “Opportunity Zone Fund” (a...more
On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....more
Real estate developers, fund sponsors, and property owners have been eagerly awaiting guidance on the new Qualified Opportunity Zone ("QOZ") provisions included in last December’s Tax Cuts and Jobs Act. ...more
Seyfarth Synopsis: On October 19, 2018, the U.S. Department of the Treasury released long-anticipated proposed regulations (the “Proposed Regulations”) relating to investments in Qualified Opportunity Zones (“QOZs”)....more
The Tax Cuts and Jobs Act introduced a new tax-incentive program known as Qualified Opportunity Zones (QOZs). In 2018, governors of all 50 states, the District of Columbia, and the five U.S. possessions designated more than...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...more
The new rules address a number of issues that investors and sponsors were waiting for guidance on. The IRS has promised further guidance to address issues that remain in need of clarification. ...more
On Friday, October 19, 2018, the U.S. Treasury Department issued long-awaited proposed regulations and other guidance with respect to opportunity zone incentives under Internal Revenue Code (I.R.C.) § 1400Z-2....more
The Treasury Department has released guidance for the new opportunity zone (OZ) tax incentive, which addresses gains invested in qualified opportunity funds (QOF)...more
The 2017 Tax Cut and Jobs Act included significant new tax benefits for investments in qualified opportunity zones. Specifically, taxpayers can defer tax recognition on capital gains when the gains are reinvested in a...more
Treasury issued long-awaited Proposed Regulations and a Revenue Ruling today (October 19, 2018) regarding key issues involved with investing in and forming Qualified Opportunity Zone Funds (“OZ Fund”) and the OZ Fund’s...more
The Tax Cuts and Jobs Act added the Opportunity Zones concept as Section 1400Z to the Internal Revenue Code, which is designed to incentivize private investment in low income areas. That section of the Code allows the...more
The recently enacted Tax Cuts and Jobs Act (the “Act”) created a new program to spur economic development by providing investors with significant tax benefits for investments in designated low-income census tracts known as...more
The 2017 Tax Cuts and Jobs Act provides tax incentives for investments in “Opportunity Zones,” in an effort to promote economic development in the selected communities. Investors can reduce by up to 15 percent taxes on...more
The recent federal tax reform bill included provisions creating a new program through which a taxpayer can defer income tax on capital gains. The Opportunity Zone program allows a taxpayer to reinvest proceeds from the sale...more
We have published our whitepaper: Gain Deferral Using Qualified Opportunity Zone Investment Strategies Legal Update. “Qualified Opportunity Zones” are not specific to renewable energy and do not involve tax credits but...more
The 2017 Tax Act is offering a limited-time opportunity for taxpayers to defer gain on the sale of assets, reduce the gain when finally recognized and even eliminate gain on certain new investments. This is all made possible...more