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Under the One Big Beautiful Bill Act (the “OBBBA”), the qualified opportunity zone (QOZ) program will no longer sunset on December 31, 2026, as was set to be the case prior to the act’s passage. Instead, the OBBBA makes this...more
On July 4, 2025, President Donald Trump signed H.R. 1 into law, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Act). As discussed in our prior alert following the passage by the House of...more
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
Both the House’s and Senate’s budget bills would clarify that certain rules applicable to disguised payments for services and disguised sales of property between a partner and a partnership under Section 707(a)(2) are...more
Cascading pledges are frequently used in subscription finance to avoid legal impediments, avoid tax implications and mitigate prohibited transaction risk under the Employee Retirement Income Security Act of 1974, as amended...more
On May 22, 2025, the House of Representatives passed H.R. 1, the budget reconciliation bill known as the One Big Beautiful Bill Act (the Tax Bill). The Tax Bill proposes amendments to the Internal Revenue Code (the Code) that...more
The tax benefits conveyed by Section 1202 of the Internal Revenue Code to owners of qualified small business stock (QSBS) have been available to small business owners in some form since Section 1202 was first enacted in 1993....more
On May 9, 2025, House Committee on Ways and Means Chairman Jason Smith (R-MO) released a proposed 28-page tax bill, which is scheduled for markup by the House Committee on Ways and Means on May 13, 2025. Below, we highlight...more
The tax treatment of carried interest has long been a subject of political debate. Since 2007, almost annually, the taxation of carried interest has found its way into either proposed legislation or presidential budget...more
On February 6, 2025, Democratic Senators and Representatives proposed the Carried Interest Fairness Act, which would treat carried interest as ordinary income. Additionally, on the same day President Trump met with...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
For those keeping score at home, it’s currently two wins for the IRS in as many years, and nada/zilch/zero for the fund managers, at least when it comes to the limited partner exception for self-employment taxes (the “Limited...more
In 2024, several significant tax developments emerged that are set to impact the private fund industry in 2025. These changes include pivotal US Tax Court (Tax Court) opinions, updates to Internal Revenue Service (IRS) forms,...more
On December 23, 2024, the Tax Court ruled in Denham Capital Management LP v. Commissioner (T.C. Memo. 2024-114), that limited partners that actively participated in the activities of a fund manager formed as a state law...more
Real estate investors may be familiar with the acronym DST, which in the context of Internal Revenue Code Section 1031 like-kind exchanges, refers to a Delaware Statutory Trust. A 1031 DST is a vehicle by which a seller of...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
This week, the IRS issued Notice 2021-10, which extends the June 4, 2020 relief that the IRS previously granted to opportunity zone investors and qualified opportunity funds (QOFs) in response to the ongoing COVID-19...more
The US Treasury released Final Regulations providing guidance under Subchapter Z (the Opportunity Zone Provisions) of the Internal Revenue Code in December of 2019. The Final Regulations clarify many portions of two earlier...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 Qualified Opportunity Zone (“QOZ”) regime introduced as part of the 2017 Tax Cuts and Jobs Act provides three significant and distinct federal income tax benefits to encourage QOZ private investment: ..A taxpayer may...more
On April 16, 2019, Treasury issued its second set of proposed regulations (“OZ Regs 2”) regarding Section 14002 of the Internal Revenue Code of 1986, as amended (the “Code”). The OZ Regs 2 are very helpful and answer a...more
The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more
While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more
There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...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