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Qualified Opportunity Zone Update: Highlights of Treasury's Second Set of Proposed Regulations
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The Internal Revenue Service (IRS) and U.S. Department of Treasury recently issued guidance to curtail what they consider abusive basis shifting by related-party partners and partnerships. That guidance, which was issued June...more
The US Treasury Department and the IRS have released new proposed regulations on sales and exchanges of digital assets such as cryptocurrencies and Non-Fungible Tokens or NFTs. What taxes would a US taxpayer owe associated...more
The regulations are proposed to be effective when finalized, but taxpayers may generally rely on them if applied fully and consistently. What Is (and Is Not) Covered? The three-year restriction applies with respect to...more
The U.S. Treasury Department and the Internal Revenue Service recently released proposed regulations under Section 1061 of the Internal Revenue Code of 1986, as amended.1 Congress enacted Section 1061 in 2017 in order to...more
On August 14, 2020, the IRS published Proposed Treasury Regulations (the “Proposed Regulations”) under Section 1061 of the Internal Revenue Code to close the “carried interest loop hole” through which managers of investment...more
Introduction and Background - Treasury and the IRS issued proposed regulations on July 31, 2020 under Section 1061 of the Code (Proposed Regulations). Section 1061 effectively creates a three-year holding period...more
On July 31, 2020, the U.S. Internal Revenue Service (the "IRS") and the U.S. Treasury Department ("Treasury") issued proposed regulations (the "Proposed Regulations") that provide taxpayers with definitional and computational...more
The U.S. Department of the Treasury (“Treasury”) and the U.S. Internal Revenue Service (the “IRS”) on July 31, 2020 issued long-awaited proposed regulations (the “Proposed Regulations”) providing guidance under section 1061...more
On June 24, 2020, the Internal Revenue Service (the “IRS”) and the U.S. Department of Treasury (“Treasury”) issued final regulations (the “Final Regulations”) on the application of the “passthrough deduction” under Section...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
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 28 – November 1, 2019. October 30, 2019: The IRS issued an Action on Decision in which...more
For a variety of reasons, as has been widely reported, LIBOR is to cease to be published by the end of 2021 and this expected elimination of the index upon which financing transactions are based raises serious tax and non-tax...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
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
On April 17, 2019, the Treasury released long-awaited additional regulations and guidance with respect to Section 1400Z-2 of the Internal Revenue Code, concerning the Qualified Opportunity Zones (“QOZs”) Program (the...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
This newsletter discusses recent key guidance releases, regulatory changes, noteworthy news and certain upcoming compliance deadlines. Topics include: - 10 Things You Should Know About Opportunity Zones - ILPA...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
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
OVERVIEW OF QUALIFIED OPPORTUNITY ZONE PROGRAM - The Qualified Opportunity Zone (QOZ) program, introduced in 2017’s Tax Cuts and Jobs Act, is a new incentive program for investments in over 8,700 QOZs located in all 50...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