17 April 2019

BREAKING TAX NEWS | IRS proposes additional Opportunity Zone regulations

Today, the IRS released another set of proposed regulations (REG-120186-18) detailing the requirements that Opportunity Zone (OZ) investors must meet to defer the taxation of capital gains invested in a qualified opportunity fund. Among other things, the proposed regulations would:

  • Clarify the definition of "substantially all" for purposes of holding period and property use requirements
  • Identify transactions that could cause deferred gain to be taxed immediately
  • Specify how much deferred gain could be immediately taxed and when
  • Outline how to treat leased property used by a qualified OZ business
  • Define what constitutes qualified OZ business property
  • Outline how to source an OZ business's gross income

A Tax Alert on the proposed regulations is forthcoming. An invitation to a webcast on the proposed regulations will be sent soon.

Document ID: 2019-9006