Ley Mbappé
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Qualified Opportunity Zone Fund Investments
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The 2025 tax bill extends and expands the tax benefits to taxpayers that have capital gain and invest an amount equal to the realized gain to acquire an interest in a “Qualified Opportunity Fund,” which in turn invests in...more
Qualified Opportunity Funds (QOFs) offer generous tax incentives but are bound by a complicated set of rules, not to mention the complexity of Subchapter K of the Internal Revenue Code (IRC), as QOFs are typically organized...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
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
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
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
• 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
• 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