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Qualified Opportunity Zone Fund Investments
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
Nestled within the new proposed regulations issued by the IRS on April 12 (the "Proposed Regulations") that mainly address foreign investors is needed relief for current Opportunity Zone projects....more
On April 14, 2021, the Department of Treasury (“Treasury”) released proposed regulations (the “Proposed Regulations”) that, if adopted, would allow flexibility for qualified opportunity zone businesses (“QOZBs”) to revise or...more
On June 4, 2020, the Internal Revenue Service published Notice 2020-39 (Notice) which provides relief to qualified opportunity funds (QOFs) and their investors in light of the COVID-19 pandemic. Here is a summary, and more...more
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
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
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
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
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
The Treasury Department has issued two sets of proposed regulations concerning the tax benefits available to taxpayers who invest in Qualified Opportunity Funds (QOFs). The first set of proposed regulations (published in...more
Qualified Opportunity Funds - The Opportunity Zone tax incentive program allows taxpayers that invest in a Qualified Opportunity Fund to (i) defer paying taxes on the capital gain from the sale or exchange of appreciated...more
There are many complex and confusing aspects to the qualified opportunity zone (QOZ) program, and the treatment of Section 1231 gain is no exception. Internal Revenue Code Section 1231 applies to depreciable property and...more
On April 17, the Treasury Department (Treasury) released the second set of proposed regulations concerning investing in qualified opportunity funds (QOFs) and qualified opportunity zones (QOZs) under Section 1400Z-2 of the...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
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
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
Restoring accountability measures stripped during tax reform could be good news for those concerned about gentrification but may result in reputational risks and additional costs for OZ Funds - As we anticipated in our...more
Significant tax incentives for investing in qualified opportunity funds (“QOFs”) that make qualifying investments in low-income census tracts designated as qualified opportunity zones (“QOZs”) were signed into law in December...more
On April 17, 2019, the IRS issued its much anticipated second tranche of guidance (the “2019 Proposed Regulations”) on the qualified opportunity zone (QOZ) program established by the 2017 Tax Cuts and Jobs Act. ...more
Last July, I wrote a blog post on opportunity zones and the importance to investors and professionals of forthcoming guidance from the IRS. The first chapter of that guidance was issued in October 2018, and was the subject of...more
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
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
On Wednesday April 17, 2019, the IRS issued the second round of proposed Treasury Regulations for Qualified Opportunity Zones under the Tax Code (the “New Proposed Regulations”). These regulations provide some much-needed...more
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more
Perhaps Treasury intentionally waited until after March Madness to release the long-awaited second round of proposed regulations on Opportunity Zones since the proposed regulations presents its own Sweet 16. While Treasury...more