Thought Leadership


Polsinelli Commentary on the Second Round of Opportunity Zone Regulations

In this webinar, Polsinelli attorneys address the long-awaited second round of Proposed Regulations issued April 17, 2019. These regulations clarified some key issues in connection with investing in and forming Qualified Opportunity Funds (“QOF”) and the OZ Fund’s investments in Qualified Opportunity Zone Businesses (“QOZB”). Many of the topics covered in the first set of Proposed Regulations were expected and are quite favorable to investors. However, the second set of Proposed Regulations also contained some unwelcome surprises. These additional Regulations are only proposed, and are therefore subject to further revisions based on comments received by Treasury. Taxpayers can rely on many of these proposed rules, provided that the taxpayer applies the rule in its entirety and in a consistent manner.

Investment in federal opportunity zones

Treasury issued long-awaited Proposed Regulations and a Revenue Ruling October 19, 2018, regarding key issues involved with investing in and forming Qualified Opportunity Zone Funds (“OZ Fund”) and the OZ Fund’s investments in Opportunity Zone Businesses (“OZ Business”). Although the Proposed Regulations do not answer all of our key questions, Treasury did provide generally taxpayer friendly guidance to the issues discussed below.