Qualified Opportunity Zone Fund Investments
Over its nearly 40-year history, the federal low income housing tax credit (LIHTC) program has been both a success story and a target for various forms of fraud. The LIHTC program has been credited with facilitating the...more
Last year’s Inflation Reduction Act created the Low-Income Communities Bonus Credit Program. This program provides additional energy tax credits on top of the existing 30% investment tax credit. According to Section 48(e) of...more
The low-income communities bonus credit (the LIC Bonus), which was introduced by the Inflation Reduction Act of 2022 (the IRA), provides an enhanced tax credit for certain wind and solar facilities located in designated...more
The U.S. Department of the Treasury and IRS on May 31, 2023, released a Notice of Proposed Rulemaking (NPRM) regarding the low-income community bonus credit under Section 48 of the Internal Revenue Code. The NPRM requests...more
On February 13, 2023, the Department of Treasury (Treasury) and the Internal Revenue Service (Service) issued Notice 2023-17 (Notice), establishing the 48(e) Low-Income Communities Bonus Credit Program (Program) with respect...more
In 2017, the Tax Cuts and Jobs Act (the “Act”) added a third minimum set-aside option to qualify a project as a qualified low-income project pursuant to Code Section 42(g)(1)(C) - the Average Income Set-Aside. The Average...more
Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more
On January 30, 2020 the IRS recently issued Revenue Ruling 2020-4 that provides additional guidance on calculating income limit designations for units in a project that has selected the Average Income Test to qualify for the...more
The OZ Digest is a monthly update from the Polsinelli Opportunity Zones team. Our goal is to share everything opportunity zone (OZ) related from our team including firm and regulatory updates, events and thought leadership...more
BACKGROUND - Sections 1400Z-1 and 1400Z-2 were added to the Internal Revenue Code of 1986, as amended (the “Code”) by the Tax Cuts and Jobs Act. These new provisions to the Code introduce a multitude of new terms,...more
This white paper is designed to summarize the federal Opportunity Zone program to industry professionals and potential market participants. We summarize for readers the program’s tax incentive structure, how investment...more
Real estate developers, fund sponsors, and property owners have been eagerly awaiting guidance on the new Qualified Opportunity Zone ("QOZ") provisions included in last December’s Tax Cuts and Jobs Act. ...more
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
The new rules address a number of issues that investors and sponsors were waiting for guidance on. The IRS has promised further guidance to address issues that remain in need of clarification. ...more
On Friday, October 19, 2018, the U.S. Treasury Department issued long-awaited proposed regulations and other guidance with respect to opportunity zone incentives under Internal Revenue Code (I.R.C.) § 1400Z-2....more
The proposed Tax Cuts and Jobs Act released last week would eliminate the federal tax exemption for interest earned on all private activity bonds—including 501(c)(3) bonds and exempt facility bonds—and advance refunding bonds...more