News & Analysis as of

Internal Revenue Service Investment Funds Real Estate Investments

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Troutman Pepper Locke

The One Big Beautiful Bill: Initial Analysis of Key Provisions for the Real Estate Industry

Troutman Pepper Locke on

On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more

Akin Gump Strauss Hauer & Feld LLP

IRS Takes View That FIRPTA Exemption for Publicly Traded Stock Must Be Tested at Partnership Level

Key Points Internal IRS correspondence in the form of a recent Chief Counsel Memorandum concludes that funds structured as partnerships (e.g., master funds in a standard master-feeder structure) must determine the...more

Bilzin Sumberg

Proposed Regulations May Affect Taxation of Foreign Investors in REITs

Bilzin Sumberg on

On December 29, 2022 the IRS and the Treasury Department issued a notice of proposed rulemaking (REG-100442-22) (the “Proposed Regulations”) that, among other things, affects the determination when Real Estate Investment...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

Lowndes on

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

Sullivan & Worcester

Proposed Bipartisan Amendments to the Opportunity Zone Statute Could Have a Significant Effect on Current and Potential Investors

Sullivan & Worcester on

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

McDermott Will & Schulte

The Nonqualified Financial Property Limitation

McDermott Will & Schulte on

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

McDermott Will & Schulte

The 90 Percent Test

McDermott Will & Schulte on

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

Williams Mullen

Ding Dong, the OZ Ground Lease (May Be) Dead!

Williams Mullen on

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

Winstead PC

Additional Short-Term Relief Granted for Qualified Opportunity Funds and Investments

Winstead PC on

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

Stinson LLP

IRS Extends Relief for Qualified Opportunity Funds

Stinson LLP on

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

Sullivan & Worcester

Internal Revenue Service Provides Additional COVID-19 Related Relief for Opportunity Zones Investors

Sullivan & Worcester on

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

Morgan Lewis

IRS Extends Previously Issued Relief to Qualified Opportunity Funds and Their Investors

Morgan Lewis on

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

Allen Matkins

Extensions of COVID-19 Relief for Opportunity Zone Funds

Allen Matkins on

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

Lowndes

IRS Extends Much-Needed Opportunity Zone Relief

Lowndes on

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

Ruder Ware

Responding to the Pandemic, IRS Loosens Opportunity Zone Requirements

Ruder Ware on

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

Morgan Lewis

IRS Provides COVID-19 Pandemic Relief for Qualified Opportunity Zone Investments

Morgan Lewis on

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

Weintraub Tobin

Opportunity Zone Funds And Investors Get Relief In Light Of COVID-19

Weintraub Tobin on

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

Greenberg Glusker LLP

IRS Grants Additional Relief for Qualified Opportunity Funds

Greenberg Glusker LLP on

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

Ballard Spahr LLP

IRS Further Extends Qualified Opportunity Zone Deadlines

Ballard Spahr LLP on

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

Sullivan & Worcester

IRS Provides Relief to Opportunity Funds and OZ Investors

Sullivan & Worcester on

As part of its continuing response to the COVID-19 pandemic, on June 4, 2020, the Internal Revenue Service issued Notice 2020–39 (the “Notice”). The Notice provides welcome relief to Qualified Opportunity Funds (“QOFs”) and...more

Maynard Nexsen

Deadlines Extended – IRS Provides Relief to Qualified Opportunity Funds and its Investors

Maynard Nexsen on

On June 4, 2020 the IRS released Notice 2020-39 (the Notice) providing relief to Qualified Opportunity Funds (QOFs) and their investors in response to COVID-19. The Notice provides that the 180-day investment period for...more

Pierce Atwood LLP

IRS Provides Relief on Opportunity Zone Deadlines

Pierce Atwood LLP on

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

Lowndes

IRS Provides Much-Needed Opportunity Zone Relief

Lowndes on

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

Greenberg Glusker LLP

IRS Extends Deadlines for IRC §1031 Exchange Transactions and Qualified Opportunity Fund Investments

Greenberg Glusker LLP on

On April 9, 2020, the IRS issued Notice 2020-23 providing sweeping tax filing and tax payment deferral until July 15, 2020. This relief includes extensions of the 45- and 180-day deadlines for IRC §1031 exchange transactions...more

Polsinelli

Polsinelli Commentary on the Final Opportunity Zone Regulations

Polsinelli on

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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