In the Zone: GT Qualified Opportunity Zone News – April 2019

Posted in Opportunity Zones, qualified opportunity funds, qualified opportunity zones, real estate tax, Tax Cuts and Jobs Act

Welcome to In the Zone: GT Qualified Opportunity Zone News. Our monthly digest of the latest federal and state developments in Qualified Opportunity Zones and Qualified Opportunity Funds and related Greenberg Traurig news and events will keep stakeholders apprised of the most pressing issues in this burgeoning space.

At the White House

 HOT DOCSTreasury issues second round of regulations and wants public comment measuring the economic impact of QOZs.

GT Alert > Highly Anticipated Qualified Opportunity Zone Proposed Treasury Regulations Released <

In early April, President Trump named Scott Turner as the new Executive Director of the White House Opportunity and Revitalization Council.

The Administration strongly supports QOZ.

REVITALIZING AMERICAN COMMUNITIES: Opportunity Zones are a critical part of President Trump’s efforts to bring economic opportunity to communities that have been left behind.

  • The Tax Cuts and Jobs Act (TCJA) included a new Opportunity Zones incentive designed to bring investment to struggling communities across the country.
  • Under the TCJA, investors can get tax benefits by investing in communities designated as Opportunity Zones.
    • Investors receive tax benefits on capital gains that they reinvest into Opportunity Zones through investment vehicles called Qualified Opportunity Funds.
    • These benefits are structured to promote long-term investment that will help these communities recover and thrive.
  • All states, territories, and the District of Columbia nominated low-income communities to be designated as Opportunity Zones.
  • 8,762 communities home to nearly 35 million Americans have now been designated.
  • Opportunity Zones will help encourage investors to fund new businesses, develop properties, and finance construction in these struggling communities.

https://www.whitehouse.gov/briefings-statements/tax-cuts-jobs-act-generating-economic-resurgence-communities-across-country/

On April 17, the President participated in another community group outreach event on QOZs at the White House.

In the Agencies

Treasury announced the highly anticipated second round of regulations at the White House event April 17. Read about it here as well. Treasury also wants public comment on how to measure the economic impact of QOZs

HUD is asking for public comment on its existing policies, practices, planned actions, regulations, and guidance regarding HUD-administered programs and laws to identify actions HUD can take to encourage beneficial investment, both public and private, in urban and economically distressed communities, including qualified Opportunity Zones. HUD seeks input and recommendations from the public regarding potential agency actions.

In Congress 

Legislation introduced to apply Opportunity Zones to areas struggling with disaster recovery.

Upcoming Events 

Speaking Engagements

  • May 21: Opportunity Zone Summit at Dr. Phillips, Inc. Foundation with SunTrust Bank, 12:00 – 1:00 ET – James Lang
  • May 21: KBKG Opportunity Zone Deals, Separating Facts From Fiction: An Interactive Discussion with Thought Leaders in the OZ World, James Lang, Sandy Present, and Ryan Bailine, Online Webinar, 1:00 – 2:00 PT.
  • May 22: “Hold For” GT In-house Webinar on OZ – James Lang
  • June 2 to June 4: 41st Annual NYU International Hospitality Industry Investment Conference, New York Marriott Marquis – James Lang
  • June 20: Strafford CLE Webinar:  Qualified Opportunity Zones: New Tax Incentives, 1:00 – 2:30 EDT – James Lang

QOZ Conferences

  • April 25 to April 26: Novogradac OZ, Denver
  • May 9 and May 10: Opportunity Zone Expo, Las Vegas, Mandalay Bay

 For additional information, please contact Sharon Mangione.

Highly Anticipated Qualified Opportunity Zone Proposed Treasury Regulations Released

Posted in Opportunity Zones, qualified opportunity funds, qualified opportunity zones, Real Estate, real estate tax

On Wednesday, April 17, the United States Department of the Treasury released proposed regulations related to investment in Qualified Opportunity Zones and Qualified Opportunity Funds. The issuance of these highly anticipated regulations and related guidance will provide critical information to investors, Qualified Opportunity Funds, and project sponsors/operators involved in real estate, venture capital, operating business, and project finance in Qualified Opportunity Zones. Of particular importance in this release is guidance relating to the qualification criteria for operating businesses and venture capital. The release also provides further clarity in the qualification criteria for real estate development projects. Greenberg Traurig has broad experience working with clients in fund formation and investor utilization, along with sponsor, developer, and operator project qualification under this new tax incentive program.

Click here for the full GT Alert, which includes a link to and highlights of the proposed regulations.

Veterans Housing Preference Permitted Under IRC Section 42 Now Permitted Under 142

Posted in GT Alert, Internal Revenue Code, tax-exempt bonds

On April 3, 2019, the IRS released Revenue Procedure 2019-17, providing that the general public use requirement of section 142(d) of the Internal Revenue Code (relating to residential rental projects) permits the use of housing preferences and occupancy restrictions consistent with the provisions of the low-income housing tax credit requirements under section 42(g)(9) of the Code. This issue has become a point of interest for housing developers given a recent focus on the needs of veterans and other groups that have particular trouble locating affordable housing.

To read the full GT Alert, click here.

In the Zone: GT Qualified Opportunity Zone News – March 2019

Posted in Opportunity Zones, qualified opportunity funds, qualified opportunity zones, real estate tax

Welcome to In the Zone: GT Qualified Opportunity Zone News. Our monthly digest of the latest federal and state developments in Qualified Opportunity Zones and Qualified Opportunity Funds and related Greenberg Traurig news and events will keep stakeholders apprised of the most pressing issues in this burgeoning space.

Legislative Updates

On Capitol Hill, Opportunity Zones continue to get a lot of attention and discussion before Tax Committees. On March 14 Treasury Secretary Mnuchin appeared before the House Ways and Means and Senate Finance Committees. There was good discussion and interest level in House Ways and Means on Opportunity Zones as the new Democrat majority assesses this component of the Tax Cuts and Jobs Act, looking to determine effectiveness in achieving new majority goals.

OMB still has the most recent Opportunity Zones rule under consideration:

AGENCY: TREAS-IRS RIN: 1545-BP04 Status: Pending Review
TITLE: Qualified Opportunity Funds [TCJA]
STAGE: Proposed Rule ECONOMICALLY SIGNIFICANT: No
RECEIVED DATE: 03/12/2019 LEGAL DEADLINE: Statutory

Past Events

Thanks to our partners for a successful event in Northern Virginia: Life Cycle of a Serial Entrepreneur – Just in Time: Qualified Opportunity Zone. 

Our panelists discussed the most recent tax legislation regarding robust tax benefits when investing in Qualified Opportunity Zones. If you’ve recently sold your company or investment for a sizable capital gain, investing in a Qualified Opportunity Fund can be an effective strategy to reduce the upcoming tax bill by deferring the gain. But timing is crucial as the tax benefits are tied to a 180-day window to invest in an Opportunity Zone Fund.

 

 

 

 

 

 

 

 

 

 

 

 

 

Upcoming Events

  • April 8: Miami-Dade County Opportunity Zones Conference & Marketplace presented by Madison Street Strategies, with James O. Lang
  • May 2: Ozone Breakfast sponsored by SunTrust and the Dr. Phillips Foundation for Orlando Not-for-Profit Entities, with James O. Lang
  • May 9 & 10: Opportunity Zone Expo, Las Vegas, Mandalay Bay, with James O. Lang
  • May 21:  Opportunity Zone Online Presentation with  Ryan D. Bailine  and James O. Lang
  • June 2-4: 41st Annual NYU International Hospitality Investment Conference, New York Marriott Marquis with James O. Lang.

For additional information, please contact Sharon Mangione.

GT Supports NYU Winthrop Hospital’s 22nd Annual A Cause to Celebrate…Child Life

Posted in Firm News

Greenberg Traurig was a proud sponsor of NYU Winthrop Hospital’s 22nd Annual “A Cause to Celebrate” on March 21, 2019, in New York. The gala honored the Founder/CEO of Fareportal, Sam Jain, and his wife, Vera Jain, for their contributions. The firm’s participation benefitted the hospital’s Child Life Program and celebrated the Jain family. Lucy S. Lee (Shareholder, Northern Virginia and Washington, D.C., Tax) attended on behalf of GT.

Pictured Immediately Below: Sam Jain (honoree and Founder/CEO of Fareportal), David Orleans (Managing Director of Citi Private Bank), Lucy S. Lee, Harvey Tanton (Managing Partner of Tanton Grubman LP), and Rob Grubman (Partner of Tanton Grubman LP).

Pictured at Bottom: Matt Blance-Stephany (Voyager HQ), Rob Grubman (Partner of Tanton Grubman LP, Harvey Tanton (Managing Partner of Tanton Grubman LP), Lucy S.Lee, David Orleans, Jim Givens (Partner of Ernst & Young LLP), Mike Persinski (Managing Director of Citi Private Bank), Anta Cisse-Green (Associate General Counsel of NYU Langone), and Amanda Miller (Associate General Counsel of NYU Langone).

Lucy Lee Receives 2 Korean Tax Authority Awards

Posted in awards

Lucy S. Lee (Shareholder, Northern Virginia and Washington, D.C., Tax) was recently recognized by the Korean Tax Authority. The Commissioner of the National Tax Service of Korea, Han Sung Hee, presented Lucy with an Award of Distinguished Service and Contribution to the advancement of international tax policies and administration, and a Plaque of Appreciation in recognition of distinguished support and devotion to the development of friendship and mutual cooperation between Korea and the United States.

The awards, pictured below, were presented to Lucy by Ambassador Hyo-Sung Park and Consul Insup Lee in an awards ceremony attended by other dignitaries and press.

Greenberg Traurig Attorney Lucy Lee Quoted in the Wall Street Journal

Posted in Estate Planning, International Tax, Legacy Planning

Lucy S. Lee, shareholder of Greenberg Traurig’s Tax Practice, was recently quoted in the Wall Street Journal article, “Meghan Markle Is About to Have a Little Bundle of Tax Headaches.” The article discusses what tax concerns Meghan and her baby will have being a U.S. citizen with a British royal husband/father.   

To read the full article, please click here. (subscription required)

 

Part 2: In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Proposed Reissuance Regulations

Posted in GT Alert, Internal Revenue Code, IRS, Tax Planning, tax-exempt bonds

The Department of the Treasury and IRS provided two New Year’s Eve presents to the tax-exempt bond community. One was the finalization of the public notice regulations, and the second was the issuance of the proposed reissuance regulations, both of which have been long promised, and both of which were published in the Federal Register on Dec. 31, 2018. This GT Alert addresses the proposed reissuance regulations.

The Proposed Reissuance Regulations

The Treasury and IRS published proposed regulations (the Proposed Regulations) under §§150 and 1001 of the Internal Revenue Code of 1986, as amended (the Code), proposing rules for when bonds are deemed retired and reissued. These regulations generally follow existing guidance with some technical changes.

To read the full GT Alert, click here.

In the Midst of a Federal Government Shutdown, Tax-Exempt Bond Community Receives Long-Awaited Final Public Notice and Approval Regulations

Posted in GT Alert, Internal Revenue Code, IRS, Tax Planning, tax-exempt bonds

The Department of the Treasury and IRS provided two New Year’s Eve presents to the tax-exempt bond community. The first is the finalization of the public notice and approval regulations, commonly referred to as the TEFRA Regulations (the Final Regulations), and the second is the issuance of the proposed reissuance regulations. Both developments have been long promised, and both were published in the Federal Register on Dec. 31, 2018. This GT Alert updates the GT Alert published on Sept. 29, 2017, which described proposed public notice and approval regulations issued in 2017 (the 2017 Proposed Regulations), to identify changes that the Final Regulations made to those Proposed Regulations. A separate GT Alert will address the proposed reissuance regulations.

To read the full GT Alert, click here.

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