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One of the highly anticipated provisions of the One Big Beautiful Bill Act (OBBBA) is the extension and expansion of the Opportunity Zone (OZ) program, which was originally enacted under the Tax Cuts and Jobs Act of 2017...more
The Opportunity Zone program (the “OZ Incentive Program”), launched under the 2017 Tax Cuts and Jobs Act, was designed to spur economic development in distressed communities by offering tax incentives to investors. As part of...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
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
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
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
Offering significant tax breaks for investors, the federal Qualified Opportunity Zone (QOZ) program is an intriguing prospect for real estate developers and investors. However, the Treasury Department is still formalizing the...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
The Treasury Department and the Internal Revenue Service (IRS) recently released much-anticipated proposed regulations, as well as a related revenue ruling (Rev. Rul. 2018-29), concerning opportunity zone investments....more
The Internal Revenue Service (IRS) recently issued significant guidance regarding the implementation of the 2017 Tax Act provisions involving opportunity zones and the potential for both capital gain deferral and capital gain...more
On October 19, 2018, the U.S. Treasury Department (“Treasury”) and the Internal Revenue Service issued proposed regulations for the new Opportunity Zone tax incentive. Opportunity Zones are a powerful new economic development...more
On October 19, 2018, the Internal Revenue Service (the “IRS”) and the Treasury Department issued proposed regulations relating to the new Opportunity Zone program....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
On October 19, 2018, the IRS issued highly anticipated proposed regulations on opportunity zones. The guidance and interpretations in these regulations provide a clearer path for investment in the new “Opportunity Zone”...more
On October 19, the Treasury Department released a first round of guidance bringing much needed clarity to certain aspects of the Qualified Opportunity Fund regime enacted by the Tax Cuts and Jobs Act. While important...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...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 Tax Cuts and Jobs Act created the Opportunity Zone program, which was designed to encourage investment in economically distressed communities by allowing taxpayers to defer and potentially exclude certain portions of...more
• Holland & Knight previously published a three-part series describing the powerful new tax incentive contained in the Tax Cuts and Jobs Act for investments in low-income communities designated as "Opportunity Zones." •...more
On October 19th, 2018, the Department of Treasury released the first set of proposed regulations and a related revenue ruling for the opportunity zone incentives created by the Tax Cuts and Jobs Act of 2017, which was enacted...more
Introduction - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury are still figuring out the details of how...more
The “Opportunity Zone Program” (“OZP”) was enacted as part of the Tax Cuts and Jobs Act of 2017 and is the first new economic development tax incentive program since the New Markets Tax Credits Program was enacted in 2000....more