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
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
REITs, or real estate investment trusts, are often described as a mutual fund for real estate. Congress established REITs to allow individual investors to invest in large-scale, income-producing real estate. Since their...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
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 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
As a result of the continuing COVID-19 impact on qualified opportunity funds (“QOFs”) and prospective investors therein, the IRS recently issued Notice 2021-10 (the “Notice”) in order to grant additional relief to QOF and...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
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
In IRS Notice 2021-10 (the New Notice), the IRS granted relief to Opportunity Zone Funds because of the COVID-19 pandemic. The New Notice generally extends the relief that had previously been granted pursuant to IRS Notice...more
This week, the IRS issued Notice 2021-10, which extends the June 4, 2020 relief that the IRS previously granted to opportunity zone investors and qualified opportunity funds (QOFs) in response to the ongoing COVID-19...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 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
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