Final opportunity zone regulations have been released Stakeholders interested in maximizing tax incentives must initiate an investment prior to the end of the year.
from this blog
21 December 2019IRS Issues Final Regulations on OZones + Qualified Opportunity Funds
IRS has issued final regulations on Qualified Opportunity Funds, nearly two years after the Opportunity Zone initiative was enacted into law as part of the 2017 Tax Cuts & Jobs Act.
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There are a number of sticking points from the first two tranches of proposed regulations — many of which were discussed at the most recent IRS hearing on Qualified Opportunity Funds — that should be clarified in these final regs, including:
- Data collection and reporting, and what Treasury’s limits may be.
- Multi-asset fund exit options, and the discrepancies that exist between tax treatment at the different QOF, QOZB, and QOZBP levels.
- Whether the substantial improvement test can be conducted on an aggregate basis, as opposed to an asset-by-asset basis.
- The treatment of debt-financed distributions.
- The treatment of Section 1231 gains.
- The definition of vacant property.
- How to pair the Opportunity Zone tax incentive with real estate tax credits such as New Markets, Low Income Housing, Renewable Energy, and Historic.
Click here to read the complete draft of the final regulations.
The final regulations are a modification and merger of the first and second tranches of regulatory guidance and provide additional clarification on topics that remained unresolved after the first two sets of proposed regulation.
In total, the notice is 544 pages in length.
IRS completed the final regulations and submitted them for review to the Office of Information and Regulatory Affairs (OIRA) on December 6.
The final regulations do not officially take effect until they are published in the Federal Register.
The final regulations are a modification and merger of the first and second tranches of regulatory guidance and provide additional clarification on topics that remained unresolved after the first two sets of proposed regulation.
In total, the notice is 544 pages in length.
IRS completed the final regulations and submitted them for review to the Office of Information and Regulatory Affairs (OIRA) on December 6.
