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Unpacking Treasury's New Opportunity Zone Rules

Law360 (May 23, 2019, 3:57 PM EDT) -- The U.S. Department of the Treasury and Internal Revenue Service recently issued a second round of proposed regulations providing additional guidance for qualified opportunity fund investors and sponsors, and supplementing the initial proposed regulations issued in October of 2018 under Sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended. Subject to certain exceptions, taxpayers generally may rely on the proposed regulations as long as they follow the relevant section in its entirety in a consistent manner.

The proposed regulations clarify several significant points but leave many open questions. We expect that the proposed regulations will boost the...

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