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
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
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
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
Investors, fund sponsors, real estate developers, and businesses using or planning to use the Opportunity Zone incentive (the OZ Incentive) should be aware of some upcoming critical dates. Some of these dates are the result...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
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
On January 20, 2021, the Treasury Department published Notice 2021-10, extending COVID-19 relief for qualified opportunity funds (QOFs) and their investors. The new guidance generally extends the relief already in effect...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
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
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
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
In December 2019, the Treasury released final regulations for the opportunity zone program (the "Final Regulations") to refine and clarify certain aspects of the first two sets of proposed regulations and to make the rules...more
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
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
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
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
In Notice 2020-39, which was released on Thursday, June 4, 2020, the IRS provided critical relief to qualified opportunity zone (OZ) investors, qualified opportunity funds (QOF) and OZ businesses due to the COVID-19...more
In Notice 2020-39, issued on Thursday, June 4, 2020, the IRS made substantial accommodations to Qualified Opportunity Funds, and their sponsors and investors, to allow them to address the challenges presented by COVID-19....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
The Sullivan Opportunity Zone Practice Group has previously written a client alert promoting the benefits of detailed record-keeping for taxpayers operating in the OZone world. There are certain specific records that are...more
How will the United States recover from the COVID-19 pandemic? At least part of the answer may be by making a few critically important tweaks to the Opportunity Zone tax incentives contained in Code Section 1400Z-2 (the “OZ...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
...more