Qualified Opportunity Zone Update: Highlights of Treasury's Second Set of Proposed Regulations
Qualified Opportunity Zone Fund Investments
Opportunity Zones (OZs) and their tax incentives haven’t been getting much notice these days in either business or legal media. If pending legislation passes, this will likely change and bring new attention to this...more
A Qualified Opportunity Zone (QOZ) is an economically distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment. The U.S. federal government created this tax...more
On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more
While investments in Qualified Opportunity Funds may continue to be made well after the end of 2021, the 10% tax reduction on the capital gains invested in the Qualified Opportunity Fund will be gone by December 31, 2021. If...more
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
A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met,...more
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
As has been the case over the last couple of years, opportunity zone (“OZ”) investments have been the subject much interest from taxpayers and investors during 2021. This interest has led to the investment of significant...more
The upcoming deadline to make a “capital gain rollover” investment into a “qualified opportunity fund” with respect to certain 2020 pass-through gains is September 10, 2021. Most commonly, this deadline applies to capital...more
The Biden tax reform proposals target many tax benefits associated with real estate investing. If adopted, the ability to do tax free like kind exchanges may be eliminated and the maximum long term capital gains rates on...more
Although it is unclear what will happen to capital gains rates over the course of the next year, it is important to discuss the implications of what a rate hike could mean. While we don’t know for certain whether the capital...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
On January 20, 2021, the Treasury Department published Notice 2021-10, extending COVID-19 relief for qualified opportunity funds (QOFs) and their investors. The new guidance generally extends the relief already in effect...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
On January 19, 2021, the IRS published guidance in Notice 2021-10, extending critical deadlines and rules relating to investments in qualified opportunity zones. First, any investors facing a deadline between April 1, 2020,...more
The District of Columbia is implementing certain new regulations and has also enacted new legislation that will likely result in a reduction in expected investment returns and create overly burdensome government oversight...more
The Tax Cuts and Jobs Act created opportunity zones as an economic development tool to stimulate investments in distressed communities. This tool extends tax advantages to investors in qualified opportunity funds, provided...more
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
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
The IRS recently issued additional Opportunity Zone-related guidance, Notice 2020-39, that grants extension relief with respect to five specific time-sensitive actions. Among other things, Notice 2020-39 (i) allows certain...more
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
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