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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
The Chancellor’s radical tax cutting 'mini-budget' on 23 September introduced the new government’s central agenda for growth. Whilst it was the fiscal announcements that have since dominated the headlines and market reaction,...more
Ohio’s General Assembly recently voted to temporarily double its Ohio Historic Preservation Tax Credit (OHPTC) award cap and increase, then reduce Ohio’s Opportunity Zone (OZ) Tax Credit cap. For state fiscal years 2023 and...more
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
In 2017, the Tax Cuts and Jobs Acts (TCJA) created a capital gains investing program aimed at revitalizing impoverished neighborhoods in the United States, known as “Qualified Opportunity Zones.” The purpose of this program...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
From the date of its inception, the Opportunity Zone Program has been criticized for its lack of transparency and reporting requirements. The original version of the law included reporting requirements, but some of those...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
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
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
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
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
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
In December 2019, the Treasury released final regulations for the opportunity zone program (the "Final Regulations") to refine and clarify certain aspects of the first two sets of proposed regulations and to make the rules...more
Some rare last-minute SEC intervention forced Hertz to suspend its planned sale of up to $500 million in shares of the bankrupt car-rental company while the agency undertakes a closer review of the offering....more
The IRS issued Notice 2020-39 on June 5, 2020, to provide relief from certain deadlines under Section 1400Z-2 of the Internal Revenue Code of 1986 and the U.S. Department of the Treasury regulations thereunder (the...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
On June 4, 2020, the IRS issued Notice 2020-39, which provides important relief to qualified opportunity zone investors (“QOZ Investors”), qualified opportunity funds (“QOFs”) and qualified opportunity zone businesses...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