News & Analysis as of

Tax Cuts and Jobs Act Tax Deferral

Kerr Russell

The One Big Beautiful Bill Act Recharges Qualified Opportunity Zones

Kerr Russell on

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

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

Rivkin Radler LLP on

In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Rivkin Radler LLP

Enough Already – Eliminate Downward Attribution and Accidental CFCs

Rivkin Radler LLP on

It’s Complicated- The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more

Lowndes

Bipartisan Bill Proposes Changes to Opportunity Zone Benefits

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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

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Final Regulations on Timing of Income Recognition Provide Much-Needed Clarity, But Leave Some Questions Unanswered

On December 21, 2020, the Treasury Department (Treasury) and the IRS released final regulations (Regulations) under Section 451 for determining the taxable year in which an amount must be reported as gross income on the...more

Foley & Lardner LLP

Speculation on the Content and Timing of Potential Tax Law Changes in 2021 and 2022

Foley & Lardner LLP on

The November 3 election may have dramatic impacts on the income and estate tax laws. These changes could become effective as early as January 1, 2021. Of course, a big uncertainty is the outcome of the election, and whether...more

Eversheds Sutherland (US) LLP

“But wait, there’s more.” – Rev. Proc. 2020-39 provides guidance on the proper treatment of excess deferred taxes, and other...

On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more

Farella Braun + Martel LLP

Treasury Grants Relief to Opportunity Zone Investors in Light of Coronavirus Pandemic

The Tax Cuts and Jobs Act created opportunity zones as an economic development tool to stimulate investments in distressed communities. This tool extends tax advantages to investors in qualified opportunity funds, provided...more

Rosenberg Martin Greenberg LLP

Pertinent Tax Provisions of the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”)

The President recently signed into law the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” or “the Act”).  The following summarizes key tax provisions. Business Tax Provisions - Employee Retention...more

Greenberg Glusker LLP

Tax Implications of COVID-19 Relief Package

Greenberg Glusker LLP on

This client alert summarizes recent federal tax changes that are intended to provide relief to businesses and individuals impacted by the coronavirus (“COVID-19”) epidemic, including changes effected under recent IRS...more

Bradley Arant Boult Cummings LLP

Stimulus Tax Relief Provisions Under New CARES Act

The landmark 335-page Coronavirus Aid, Relief, and Economic Security Act (CARES Act), signed into law on March 27, 2020, is an estimated $2+ trillion package primarily devoted to providing economic relief and stimulus for...more

Neal, Gerber & Eisenberg LLP

The CARES Act Offers a New Tax Planning Opportunity

One provision of the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) involves a "real estate" tax break, which is actually much broader and applies to many taxpayers, and may require the filing of amended tax...more

Orrick, Herrington & Sutcliffe LLP

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

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

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

Foster Garvey PC

Be Careful What You Wish For – What May Be Good for Federal Income Tax Purposes May Not Be So Good For Purposes of the Oregon CAT

Foster Garvey PC on

I apologize in advance for focusing my blog these past several weeks on the new Oregon Corporate Activity Tax (“CAT”), but my mind keeps finding new facets to this tax regime that I suspect most tax practitioners and even the...more

Seyfarth Shaw LLP

Final Regulations Clarify and Liberalize Many Rules Governing Qualified Opportunity Fund Formation and Operations

Seyfarth Shaw LLP on

Seyfarth Synopsis: On December 19, 2019, the U.S. Treasury issued final Qualified Opportunity Zone regulations (the “Final QOZ Regulations”). Subject to the commentary in the Preamble to the Final QOZ Regulations on circular...more

Jackson Walker

Treasury Releases Final Regulations for Investing in Qualified Opportunity Zones

Jackson Walker on

On December 19, 2019, the Treasury Department released final regulations on the Qualified Opportunity Zone (QOZ) program first enacted in the Tax Cuts and Jobs Act of 2017. Final regulations provide additional safe harbors...more

Lowndes

Industry News Briefs

Lowndes on

Happy New Year! Did I Miss My Chance at Opportunity Zones? Opportunity zones were introduced in 2017 as part of President Trump’s tax reform bill. Taxpayers with capital gains can receive several tax benefits if the...more

Ballard Spahr LLP

Treasury Releases Final Regulations On Qualified Opportunity Zone Program

Ballard Spahr LLP on

The U.S. Department of Treasury published Final Regulations for the Qualified Opportunity Zone (QOZ) program on January 13, 2020, which answer many, but not all, of the questions arising from the Proposed Regulations released...more

Blank Rome LLP

IRS Publishes Final Opportunity Zone Regulations

Blank Rome LLP on

On December 19, 2019, the Treasury Department and Internal Revenue Service (the “IRS”) released final regulations for the opportunity zone (“OZ”) program to refine and clarify certain aspects of the first two sets of proposed...more

Stinson LLP

Opportunity Zone Final Guidance

Stinson LLP on

The Treasury Department released final Opportunity Zone regulations on December 19, which combine and clarify the prior two sets of guidance, as well as an FAQ summary....more

McDermott Will & Schulte

Weekly IRS Roundup December 16 – 20, 2019

McDermott Will & Schulte on

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of December 16 – 20, 2019. December 16, 2019: The IRS released a notice extending the phase-in...more

Lowndes

Important Year End Deadline for Opportunity Zones

Lowndes on

Opportunity zones provide a powerful tool for taxpayers to defer recognizing their capital gains if they roll over their investment into a qualified opportunity zone fund, and offer investors the potential of avoiding...more

Partridge Snow & Hahn LLP

Final Opportunity Zone Treasury Regulations Released

On Thursday, December 19th, the U.S. Department of Treasury released the long-awaited final Opportunity Zone Treasury Regulations (the “Final Regulations”). The Final Regulations and explanatory materials that span 544 pages,...more

K&L Gates LLP

Private Fund Hot Topics - Critical and Emerging Issues: 2019 San Francisco Investment Management Conference

K&L Gates LLP on

OVERVIEW OF OZ RULES - - The OZ program was created by the Tax Cuts and Jobs Act, enacted in December 2017 to help direct economic resources to low income communities, spurring economic growth and job creation. - The...more

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