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DLA Piper

Withholding Requirements for Transfers of Venture Capital Fund Interests by Non-US Limited Partners

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The secondary market for limited partner interests in venture capital funds has witnessed robust growth in recent years as an increasing number of existing venture fund investors seek an early exit from their positions for...more

Dechert LLP

New Luxembourg-UK Double Tax Treaty Will Introduce Key Changes Including Access to Treaty Benefits for CIVs / Investment Funds

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Following the Luxembourg parliament’s ratification of the new Luxembourg-UK double tax treaty (“DTT”) on 19 July 2023, the new DTT should take effect in 2024. The UK ratified the new DTT on 7 June 2022....more

Whitman Legal Solutions, LLC

Tax Treatment of Carried Interests Not Likely to Change This Year

Just over a week ago, in Changes to Tax on Carried Interest Would Lead to Conflicts of Interest, I wrote about a proposal in Congress to modify the tax laws relating to carried interests. However, now like Ko-Ko, carried...more

McDermott Will & Emery

What Is a QOF?

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Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

McDermott Will & Emery

How to Invest in a QOF

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

World Law Group

2021 Venture Capital Guide - Canada

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World Law Group member firms recently collaborated on a Global Venture Capital Guide that covers more than 30 jurisdictions on investment approval processes, typical investment sectors and investment structures on Venture...more

Polsinelli

Opportunity Zone Deadlines Extended By COVID-19 Disaster Declarations (UPDATED)

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On January 19, 2021, the IRS published guidance in Notice 2021-10, extending critical deadlines and rules relating to investments in qualified opportunity zones. First, any investors facing a deadline between April 1, 2020,...more

Tonkon Torp LLP

Top Three Investor-Friendly Rules From The Newest IRS Opportunity Zone Notice

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The IRS issued Notice 2020-39 on June 5, 2020 in response to the COVID-19 pandemic, which extended several deadlines applicable to Opportunity Zone investments. •First, investors get more time to invest eligible gains into a...more

Haynsworth Sinkler Boyd, P.A.

Final Opportunity Zone Regulations – What Investors Need To Know

On December 19, 2019 the IRS published its final regulations on Opportunity Zones. Here are some noteworthy items in the final regulations: What types of gains may be invested and when? 1231 Gains: Section 1231 gains are...more

Orrick, Herrington & Sutcliffe LLP

Final Tax Regulations Offer More Certainty to Opportunity Zone Fund Managers and Investors

Opportunity Zone (or “OZ”) investment was hailed in 2018 and 2019 as the hottest and most innovative way of attracting significant private capital to distressed communities in the United States and its territories by offering...more

Polsinelli

Polsinelli Commentary on the Final Opportunity Zone Regulations

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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

King & Spalding

IRS and Treasury Release Final Opportunity Zone Regulations

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On December 19th, 2019, the Department of the Treasury and the Internal Revenue Service (the “IRS”) issued regulations (the “Final Regulations”) under Section 1400Z-2 of the Internal Revenue Code (the “Code”)[i] finalizing,...more

Stinson LLP

Opportunity Zone Final Guidance

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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

Lowndes

Important Year End Deadline for Opportunity Zones

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Opportunity zones provide a powerful tool for taxpayers to defer recognizing their capital gains if they roll over their investment into a qualified opportunity zone fund, and offer investors the potential of avoiding...more

Partridge Snow & Hahn LLP

Final Opportunity Zone Treasury Regulations Released

On Thursday, December 19th, the U.S. Department of Treasury released the long-awaited final Opportunity Zone Treasury Regulations (the “Final Regulations”). The Final Regulations and explanatory materials that span 544 pages,...more

Lowndes

Act Before Year-End To Maximize Opportunity Zone Tax Benefits

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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

Troutman Pepper

Highlights of New Opportunity Zone Regulations

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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

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update New Proposed Treasury Regulations (Part III)

Qualified Opportunity Funds - The Opportunity Zone tax incentive program allows taxpayers that invest in a Qualified Opportunity Fund to (i) defer paying taxes on the capital gain from the sale or exchange of appreciated...more

Harris Beach PLLC

IRS Issues Additional Qualified Opportunity Zone Regulations

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The Qualified Opportunity Zone (“QOZ”) regime introduced as part of the 2017 Tax Cuts and Jobs Act provides three significant and distinct federal income tax benefits to encourage QOZ private investment: ..A taxpayer may...more

Bradley Arant Boult Cummings LLP

Alabama Incentives Modernization Act: Alabama Makes a Push for Rural and Tech Jobs, Announces OZ Incentives - Economic Development...

In the final hour of its 2019 legislative session, the Alabama Legislature passed a bill that should be a catalyst for the state’s efforts to recruit tech companies and to attract projects to rural communities. The bill also...more

Sheppard Mullin Richter & Hampton LLP

Opportunity Zones Update: New Proposed Treasury Regulations (Part II)

Qualified Opportunity Zone Businesses - 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...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Second Set of Qualified Opportunity Zone Proposed Regulations Provide Clarity to Potential Investors

As discussed here in November (Why 2019 Will be the Year of Opportunity (Zones)), the Tax Cuts and Jobs Act created a tax-advantaged incentive program for investing in designated “qualified opportunity zones” throughout the...more

McDermott Will & Emery

Treasury Provides Additional Guidance on Opportunity Zone Provisions

The Tax Cuts and Jobs Act of 2017 introduced Opportunity Zone Provisions, IRC Sections 1400Z-1 and 1400Z-2, as an incentive to encourage investment in low-income communities. The provisions allow taxpayers to defer tax on...more

Bracewell LLP

Is the Opportunity Now a Reality? IRS and Treasury Release Second Tranche of Opportunity Zone Regulations

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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

Womble Bond Dickinson

New Opportunity Zone Regulations Provide Clarity on Open Issues for Investors

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On April 17th, 2019, the U.S. Treasury Department (the “Treasury”) and the IRS issued a second set of long-awaited proposed regulations relating to Opportunity Zone (“OZ”) tax incentives. The OZ program was established by...more

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