By Eric Kodesch (January 7, 2019, 1:55 PM EST) -- Last October, the IRS released the much-anticipated proposed regulations for the new qualified opportunity zone tax regime created by the December 2017 tax reform bill. Although there are glitches and issues to work through, the proposed regulations confirmed that the new opportunity zone tax regime provides U.S. taxpayers with a user-friendly method to obtain the significant tax benefits of (1) gain deferral, (2) partial gain elimination and (3) no tax on future appreciation (click here for our earlier article about the qualified opportunity zone regime). These benefits are also available to non-U.S. persons. Moreover, for non-U.S. persons who do not need the deferral and elimination benefits (because the U.S. does not tax the gain in the first place), the availability of the no tax on future appreciation benefit could effectively repeal the Foreign Investment in Real Property Tax Act, or FIRPTA, for investments in U.S. real property located in a QOZ....