On July 4, President Trump signed into law H.R. 1, the One Big Beautiful Bill Act (OBBBA), a sweeping 870-page piece of legislation that introduces significant changes across various areas of federal policy. While full...more
7/8/2025
/ Internal Revenue Code (IRC) ,
Investment ,
New Legislation ,
New Regulations ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Regulatory Requirements ,
Reporting Requirements ,
Tax Credits ,
Tax Planning ,
Tax Reform ,
U.S. Treasury
The Opportunity Zone program (the “OZ Incentive Program”), launched under the 2017 Tax Cuts and Jobs Act, was designed to spur economic development in distressed communities by offering tax incentives to investors. As part of...more
7/1/2025
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment ,
Opportunity Zones ,
Proposed Legislation ,
Real Estate Development ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
Seyfarth Synopsis: On June 12, 2020, the US Department of Treasury (the “Treasury”) promulgated proposed treasury regulations (the “Proposed Regulations”) under section 1031 (“Section 1031”) of the Internal Revenue Code of...more
On April 9, 2020, the Secretary of the U.S. Department of Treasury (the “Secretary”) and the Internal Revenue Service (the “IRS”) issued Notice 2020-23 (the “Notice”), which extends the deadline for performance of a long list...more
4/13/2020
/ Coronavirus/COVID-19 ,
Corporate Taxes ,
e ,
EDD ,
Filing Deadlines ,
Franchise Tax Board ,
HDHP ,
Income Taxes ,
Installment Agreements ,
IRS ,
Relief Measures ,
State of Emergency ,
State Taxes ,
Tax Debt ,
Tax Returns ,
Time Extensions ,
U.S. Treasury
Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more
1/21/2020
/ Anti-Abuse Rule ,
Capital Gains ,
Community Development ,
Construction Project ,
Economic Development ,
Exit Strategies ,
Final Rules ,
Investment Funds ,
IRS ,
Opportunity Zones ,
Qualified Opportunity Funds ,
Real Estate Development ,
Real Estate Investments ,
Regulatory Standards ,
Safe Harbors ,
Subsidiaries ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Planning ,
Taxation ,
U.S. Treasury
Seyfarth Synopsis: On October 19, 2018, the U.S. Department of the Treasury released long-anticipated proposed regulations (the “Proposed Regulations”) relating to investments in Qualified Opportunity Zones (“QOZs”)....more
10/29/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
Investment Funds ,
Investment Opportunities ,
IRS ,
Low Income Housing ,
Low-Income Issues ,
New Market Tax Credits ,
Opportunity Zones ,
Proposed Regulation ,
Public Finance ,
Real Estate Development ,
State and Local Government ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Incentives ,
Tax Reform ,
U.S. Treasury
Seyfarth Synopsis: On October 13, 2016 the IRS and Treasury Department published over 500 pages of final and temporary regulations under Code Section 385 (the “Final Regulations”). Drafted to curtail tax benefits accrued by...more
11/7/2016
/ Cross-Border Transactions ,
Debt Financing ,
Debt-Equity ,
Disguised Sales ,
Disregarded Entities ,
Foreign Subsidiaries ,
Inversion ,
IRS ,
Multinationals ,
Parent Corporation ,
Partnerships ,
Proposed Regulation ,
Reclassification Rules ,
Recordkeeping Requirements ,
REIT ,
RICs ,
S-Corporation ,
Subsidiaries ,
U.S. Treasury
Seyfarth Synopsis: On October 5, 2016, the Treasury Department published several pieces of guidance relating to disguised sales, allocation of liabilities, and other partnership tax issues, including “bottom-dollar”...more
Fee waivers by partners for services rendered to their partnerships will now be subject to scrutiny by the Internal Revenue Service (the “IRS”), pursuant to the Treasury Department’s notice of proposed rulemaking (the...more