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April 12, 2021

IRS proposes rules for certain foreign persons and partnerships wanting to invest in qualified opportunity funds

The IRS has issued proposed regulations (REG-121095-19) with requirements that certain foreign persons and foreign-owned partnerships must meet to make an election under IRC Section 1400Z-2 (special rules for capital gains invested in opportunity zones). The proposed regulations would allow, under certain circumstances, for withholding to be reduced or eliminated under IRC Sections 1445, 1446(a), or 1446(f) on transfers that produce gain deferred under IRC Section 1400Z-2(a). A Tax Alert on the proposed regulations is forthcoming.