Qualified Opportunity Zone Update: Highlights of Treasury's Second Set of Proposed Regulations
Qualified Opportunity Zone Fund Investments
The Opportunity Zone regime, originally established in 2017, has been permanently extended by Public Law 119-21, "An Act to provide for reconciliation pursuant to Title II of H. Con Res. 14" (the "2025 Tax Law"). The...more
The One Big Beautiful Bill Act (OBBBA) was signed into law on July 4, 2025. As part of the OBBBA, Congress has recharged and permanently extended the tax benefits offered by the Qualified Opportunity Zone (QOZ) program. ...more
There is a possibility for one or more additional reconciliation bills during late 2025 and 2026 and therefore opportunities for enactment of additional provisions, as well as changes and improvements to the Legislation....more
On July 4, President Trump signed into law the “One Big Beautiful Bill Act (OBBBA),” more formally known as “H.R.1 – An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14.”...more
The One Big Beautiful Bill Act (OBBBA), enacted in 2025, brings sweeping changes to federal tax law, impacting individuals, businesses, investors, and the clean energy sector. Below is a summary of the major updates, with...more
On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act (H.R.1) (OBBBA). This alert focuses on OBBBA changes regarding qualified small business stock (QSBS) and qualified opportunity zone (QOZ)...more
On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (OBBB), H.R. 1, into law. The OBBB extended and made permanent the general qualified opportunity fund (QOF) legislative framework for investments in...more
The opportunity zones tax incentive was enacted in 2017 as a part of the Tax Cuts and Jobs Act (the TCJA) to increase long-term investment in “qualified opportunity zones” (OZs), which are population census tracts in...more
The business tax provisions of the One Big Beautiful Bill Act (OBBBA), as signed by the president on July 4, reflect sweeping changes aimed at incentivizing small businesses, domestic investment, and manufacturing. Outlined...more
On July 4, 2025, the legislation commonly known as “The One Big Beautiful Bill Act” (the “BBBA”) was enacted. The BBBA makes permanent, extends and, in certain cases, modifies, a number of provisions from the 2017 Tax Cuts...more
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
Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...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
A Qualified Opportunity Zone (QOZ) is an economically distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment. The U.S. federal government created this tax...more
In April 2022, opportunity zone (OZ) legislation — H.R. 7467 or the Opportunity Zones Improvement, Transparency and Extension Act — was introduced, but not enacted. Among other items, that legislation included proposals to...more
On April 7, 2022 the Opportunity Zones Transparency, Extension and Improvement Act (the Bill) was introduced. The Bill is a bipartisan, bicameral bill that would extend opportunity zone tax benefits, add additional reporting...more
On April 12, 2022, the Internal Revenue Service announced that starting this month, it will send letters to taxpayers requesting that they take corrective actions related to the reporting of investments in qualified...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 10, 2022 – April 16, 2022... April 11, 2022: The IRS issued a news release, reminding...more
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
REITs, or real estate investment trusts, are often described as a mutual fund for real estate. Congress established REITs to allow individual investors to invest in large-scale, income-producing real estate. Since their...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
A brief commentary on the past week’s cases, rulings, notices, and related federal tax guidance. Medical Software Deemed a Qualifying Trade for Qualified Small Business Stock Gain Exclusion When certain criteria are met,...more