From Legislation to Implementation: Understanding Section 1202 Changes — Troutman Pepper Locke Podcast
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
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Qualified Opportunity Zone Fund Investments
Episode 26: Talking Tax Reform and Executive Comp
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Under the One Big Beautiful Bill Act (the “OBBBA”), the qualified opportunity zone (QOZ) program will no longer sunset on December 31, 2026, as was set to be the case prior to the act’s passage. Instead, the OBBBA makes this...more
The 2025 tax bill extends and expands the tax benefits to taxpayers that have capital gain and invest an amount equal to the realized gain to acquire an interest in a “Qualified Opportunity Fund,” which in turn invests in...more
Practitioners, operators and investors in the commercial real estate space are well familiar with Opportunity Zones and how they can be utilized for preferential tax treatment on investments. First created under the 2017 Tax...more
The new UK fund vehicle Reserved Investor Fund (RIF) is available beginning today, 19 March 2025. The RIF is available for all investment strategies, but what might make it an appealing option, particularly certain tax...more
Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...more
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
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
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 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
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
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
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 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
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
On June 4, 2020, in response to the ongoing COVID-19 pandemic, the IRS issued Notice 2020-39 to provide relief regarding various deadlines applicable to the federal opportunity zone program....more
On June 4, the IRS provided some much-needed relief to opportunity zone investors and qualified opportunity funds (QOFs) in response to the ongoing COVID-19 pandemic. Specifically, the IRS published Notice 2020-39, which...more
Three Flint Hill may provide valuable lessons on the use of bankruptcy to reduce real estate debt to match present property values. Chapter 11 strategies may exist for valuable real estate assets that are not producing...more
INTRODUCTION - The COVID-19 pandemic has led Governors of many states to request that their states be declared federal disaster areas. As of this writing, President Trump has declared numerous states to be federal disaster...more
Treasury issued final Opportunity Zone Regulations on December 19, 2019 (“Final Regulations”). These Final Regulations update the first two rounds of Proposed Regulations (issued on October 29, 2018 and April 17, 2019)....more
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The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...more
On December 19, 2019, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued final regulations (the “Final Regulations”) under section 1400Z-2 of the Internal Revenue Code...more