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
In April 2022, opportunity zone (OZ) legislation — H.R. 7467 or the Opportunity Zones Improvement, Transparency and Extension Act — was introduced, but not enacted. Among other items, that legislation included proposals to...more
On April 7, 2022 the Opportunity Zones Transparency, Extension and Improvement Act (the Bill) was introduced. The Bill is a bipartisan, bicameral bill that would extend opportunity zone tax benefits, add additional reporting...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
Late last week, a bipartisan group of U.S. Senators and U.S. Representatives introduced an expansive bicameral bill, titled the Opportunity Zones Transparency, Extension, and Improvement Act (the “OZ Bill”). This proposed...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
This short article outlines the requirements for starting an active business in a qualified opportunity zone (“QOZ”). The US tax legislation that created QOZs was enacted in early 2018, and is intended to encourage...more
The IRS has issued Announcement 2021-10 (the “Announcement”) in response to public questions regarding the potential effect the 2020 Census results may have on the boundaries of previously designated Opportunity Zones. ...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
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
Seyfarth Synopsis: On April 12, 2021, the Department of Treasury (“Treasury”) published proposed Treasury regulations (the “Proposed Regulations”) that (1) permit qualified opportunity zone businesses (“QOZBs”) to revise or...more
Investors, fund sponsors, real estate developers, and businesses using or planning to use the Opportunity Zone incentive (the OZ Incentive) should be aware of some upcoming critical dates. Some of these dates are the result...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
Seyfarth Synopsis: On January 19, 2021, the Internal Revenue Service (the “IRS”) issued Notice 2021-10 (the “Notice”), which extends the relief that it previously provided to qualified opportunity funds, their sponsors, and...more
On January 19, 2021, the Internal Revenue Service (“IRS”) issued Notice 2021-10 (the “Notice”), which provides relief for Opportunity Fund investors from certain deadlines and testing requirements. The relief provided by the...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