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In a recent post, available here, we discussed the basic requirements and benefits of Internal Revenue Code Section 1202, which provides for the exclusion from income of certain gains realized with respect to the sale of...more
It hasn’t taken long for the business world to start unpacking the implications of the newly passed One Big Beautiful Bill Act (OBBBA). While media coverage has mostly centered on its impact on individual taxpayers and the...more
The recently signed One Big Beautiful Bill Act (OBBBA) implements significant changes under Section 1202 of the Internal Revenue Code of 1986 (Code), applicable to qualified small business stock (QSBS) issued on or after July...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
What we'll cover: - What is Act 22? - What is Act 20? - Requirements for U.S. Taxpayer - Planning Examples...more
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
The US Senate yesterday passed a package of tax extenders as part of the year-end appropriations act that the US House of Representatives passed on December 17, 2019. President Trump is expected to sign the legislation before...more
On June 20, 2019, the Ohio Senate unanimously approved a state budget bill, House Bill 166, which includes a new tax credit for investments made into Ohio’s opportunity zones. Originally passed unanimously by the Ohio Senate...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
A Presidential Decree by Mexico President Andrés Manuel López Obrador granting a new set of income tax incentives to capital gains and interests derived from corporate bonds (the Decree) became effective on Jan. 9, 2018. ...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 Tax Cuts and Jobs Act signed on Dec. 22, 2017, amended the tax code to encourage economic growth and investment in designated distressed communities, called qualified opportunity zones, by providing federal income tax...more
• The Internal Revenue Service (IRS) on Oct. 19, 2018, issued much anticipated proposed regulations (the Proposed Regulations) and other guidance on tax benefits arising from investments in "qualified opportunity zones" that...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
• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more
Buried in an 881-page budget bill passed Thursday by the Connecticut General Assembly was a new program to support remediation and reuse of brownfields – properties long contaminated and underutilized – as well as new job...more