On January 7, 2021, the Internal Revenue Service (the “IRS”) and the Department of the Treasury released final regulations (the “Final Regulations”) implementing the provisions of Section 1061 of the U.S. Internal Revenue...more
Treasury Issues Highly Anticipated Guidance for the Implementation of Opportunity Zone Program -
On October 19, 2018, the Treasury Department issued highly anticipated guidance on investment in qualified opportunity zones...more
11/1/2018
/ Capital Gains ,
Community Development ,
Economic Development ,
IRS ,
Low Income Housing ,
New Guidance ,
Opportunity Zones ,
Proposed Regulation ,
Qualified Opportunity Funds ,
Real Estate Investments ,
Tax Cuts and Jobs Act ,
U.S. Treasury
On April 15, 2016, the IRS released a generic legal advice memorandum (GLAM 2016-001) (the “April GLAM”) addressing the impact of so-called “bad boy” guarantees (also known as nonrecourse carve-out guarantees) on the...more
Earlier this month, the IRS and Treasury Department proposed new Treasury regulations (the “Proposed Regulations”) under Section 385 of the Internal Revenue Code. The Proposed Regulations would significantly modify the tax...more