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
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
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
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 December 22, 2017, Congress enacted the Tax Cuts and Jobs Act of 2017 (the “Tax Act”). The law created a new incentive to encourage long-term investment in the nation’s low-income areas. If a taxpayer invests eligible...more
Investing in a Qualified Opportunity Fund (QOF) may be attractive to many taxpayers, but older investors may be concerned with the possibility that they may pass away while holding the QOF investment, and what that will mean...more
INTRODUCTION - On July 15, 2019, the staffs of the Securities and Exchange Commission (“SEC”) and the North American Securities Administrators Association issued a joint statement (the “Staff Statement”) to assist...more
Opportunity Zones (or OZs) may be the most talked about provision of the Tax Cuts and Jobs Act of 2017. There are many twists and turns on the yellow brick road to completing an OZ project. This article sets forth the...more
It’s hot out there and the market’s even hotter! Cool off with the latest issue of the Structured Finance Spectrum, our newsletter featuring what’s new and newsworthy in structured finance. ...more
IRC § 1400Z-2, under The Tax Cuts and Jobs Act of 2017, established an investment program designed to provide preferential tax treatment for investment in developments located within certain designated economically distressed...more
Qualified Opportunity Funds - The Opportunity Zone tax incentive program allows taxpayers that invest in a Qualified Opportunity Fund to (i) defer paying taxes on the capital gain from the sale or exchange of appreciated...more
In April, the Department of the Treasury released the much-anticipated second round of Treasury Regulations under section 1400Z-2 of the Internal Revenue Code (April Regulations). This article provides certain highlights of...more
The advent of Opportunity Zones (OZ) offers players in the private finance and real estate communities a new way to enjoy tax incentives while helping economically distressed areas. Recently, the IRS and the Treasury...more
The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for many industries, as we discussed soon after the TCJA became law. The first set of proposed regulations...more
In the final hour of its 2019 legislative session, the Alabama Legislature passed a bill that should be a catalyst for the state’s efforts to recruit tech companies and to attract projects to rural communities. The bill also...more
A new tax incentive intended to stimulate investment in low-income communities known as opportunity zones has attracted significant attention from investors, developers, and business owners since its enactment under Section...more
Qualified Opportunity Zone Businesses - BACKGROUND - In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income...more
The Opportunity Zones (“OZ”) incentive created in the 2017 Tax Cuts and Jobs Act (the “TCJA”) can be a powerful tool for renewable energy and other industries, as we discussed soon after the TCJA became law. ...more
On April 17, the Treasury Department released a second round of guidance, bringing additional clarity to the Qualified Opportunity Fund (or QOF) regime enacted by 2017’s Tax Cuts and Jobs Act. Some important questions remain...more
On Dec. 22, 2017, the Qualified Opportunity Zone tax incentive program was signed into law as part of the Tax Cuts and Jobs Act of 2017....more
Treasury Provides Additional Clarity on Opportunity Zones by Issuing Second Round of Proposed Regulations - On April 17, 2019, the U.S. Department of the Treasury issued its second set of proposed regulations (the “New...more
On April 17, 2019, the IRS released the second set of proposed regulations (REG-120186-18) which include guidance on a number of issues that the McAfee & Taft Economic Development, Tax Credits and Business Incentives...more