Which transactions qualify as section 988 transactions? In section 988 transactions, the taxpayer makes payments or receipts denominated in or determined by reference to one or more nonfunctional currency. ...more
When it comes to the taxation of stock options, the Internal Revenue Code (Code) does not define capital assets. Rather, it identifies those assets that are not capital assets. ...more
The IRS recently issued additional Opportunity Zone-related guidance, Notice 2020-39, that grants extension relief with respect to five specific time-sensitive actions. Among other things, Notice 2020-39 (i) allows certain...more
Treasury issued final Opportunity Zone Regulations on December 19, 2019 (“Final Regulations”). These Final Regulations update the first two rounds of Proposed Regulations (issued on October 29, 2018 and April 17, 2019)....more
The Treasury Department released final Opportunity Zone regulations on December 19, which combine and clarify the prior two sets of guidance, as well as an FAQ summary....more
As 2019 comes to a close, there is an important deadline approaching for opportunity zone investors. December 31, 2019 is the last day on which investors can make an investment in a qualified opportunity fund (“QOF”) and...more
In April, the Department of the Treasury released the second round of regulations related to the opportunity zone program. Some highlights include... Originally published in Middle Market Growth, the official publication...more
After months of waiting, the IRS and the Treasury Department have released a second set of proposed regulations (the “Second Tranche”) relating to the opportunity zone provisions enacted as part of the Tax Cuts and Jobs Act...more
While mid-April is typically associated by most with Tax Day, this year, April 2019, also became the month the highly awaited second round of Qualified Opportunity Zone Proposed Regulations were issued....more
BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more
Background – In December 2017, as part of the Tax Cuts and Jobs Act (“TCJA”), Congress established a new tax incentive program to promote investment in certain low-income communities designated by the IRS as qualified...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
The Tax Cuts and Jobs Act of 2017 (the “Act”) was signed into law by President Donald Trump on December 22, 2017. The Act changes many provisions of the Internal Revenue Code, from individual and business provisions, to...more
The year 2017 could be described as the year of the Bitcoin and other “virtual currencies,” with Bitcoin having appreciated 1800% since the beginning of the year and Ethereum, at one point, having appreciated 8,000% since the...more