An IRS and U.S. Treasury Department ("Treasury") notice of proposed rulemaking relating to the new Opportunity Zone tax incentive was published in the Federal Register. Comments on the proposal must be submitted by December 28, 2018.
As previously covered, the proposed regulations address, among other things, (i) the type of gains that may be deferred by investors (i.e., capital gains), (ii) investments in qualified opportunity zones ("QOFs") by pass-through entities, such as partnerships, (iii) guidance as to what constitutes opportunity zone property and what entities are eligible to be QOFs, and (iv) timing and election mechanics.
Click here to access a Cadwalader Clients & Friends Memorandum on the Proposed Regulations regarding Opportunity Zones.
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