On June 5, 2020, the Internal Revenue Service (IRS) issued Notice 2020-39 providing relief for Qualified Opportunity Funds (QOFs) and their investors (QOF investors), and clarified previously issued relief to Qualified Opportunity Zone Businesses (QOZBs) affected by the president’s declarations of major disasters caused by the Coronavirus Disease 2019 (COVID-19) pandemic (which now apply in all 50 states, Washington, D.C., and five U.S. territories).

This GT Alert summarizes the relief measures provided by the guidance. Continue reading the full GT Alert.

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Photo of James O. Lang James O. Lang

James O. Lang focuses his tax and corporate project finance practice on tax incentive programs, Qualified Opportunity Zone and Qualified Opportunity Fund financing, tax credits, and related state and federal incentive programs.  Jim is closing over $8 billion of Qualified Opportunity Funds and…

James O. Lang focuses his tax and corporate project finance practice on tax incentive programs, Qualified Opportunity Zone and Qualified Opportunity Fund financing, tax credits, and related state and federal incentive programs.  Jim is closing over $8 billion of Qualified Opportunity Funds and ancillary Qualified Opportunity Zone deployment of funds and has closed or is structuring several billion dollars in tax credit incentivized transactions.  Jim represents funds, investors, lenders, community development entities, and for-profit and not-for-profit project sponsors in complex transactions where capital stacks require enhancement through incentive financing, including Qualified Opportunity Zone incentives, state and federal new markets tax credits, affordable housing and low-income housing tax credits, historic rehabilitation tax credits, and renewable energy tax credits. He works with funds, investors, lenders, project sponsors, and qualifying businesses to structure these tax incentive programs along with ancillary governmental and non-governmental financing programs, including inbound immigration and Visa investment programs, grants, and taxable and tax-exempt bonds. Jim works with clients on developing creative structures designed to increase benefits and ameliorate risks.

Photo of Erez I. Tucner Erez I. Tucner

Erez I. Tucner is an experienced business and tax lawyer who focuses on structuring and negotiating the legal, business and tax aspects of complex multimillion-dollar domestic and cross-border mergers and acquisitions.

He has wide-ranging experience with the structuring and formation of domestic and…

Erez I. Tucner is an experienced business and tax lawyer who focuses on structuring and negotiating the legal, business and tax aspects of complex multimillion-dollar domestic and cross-border mergers and acquisitions.

He has wide-ranging experience with the structuring and formation of domestic and offshore private equity funds, family offices, and hedge funds and their investments in the United States, Latin America, Europe, Israel and worldwide.

Erez counsels high-net-worth individuals on their businesses, investment assets, and real property (including U.S. real property planning under FIRPTA).

He also represents corporate and individual taxpayers in tax audits and other tax controversy matters.

Brian Gaudet

Brian Gaudet works with private and public companies to help design tax-optimal legal entity structures and day-to-day transaction flows. Brian has wide-ranging experience handling domestic and international transactional tax work for buyers, sellers, and investors as well as experience in state & local…

Brian Gaudet works with private and public companies to help design tax-optimal legal entity structures and day-to-day transaction flows. Brian has wide-ranging experience handling domestic and international transactional tax work for buyers, sellers, and investors as well as experience in state & local tax and tax incentive work, including Qualified Opportunity Zone transactions.

Brian also has Tax & Business practice experience that includes estate planning and trust & estate administration. Brian’s Corporate practice experience includes corporate governance & compliance, mergers & acquisitions, private equity, restructuring, and real estate structuring. He approaches issues tactically, with years of experience developing practical legal strategies for clients. For more than a decade, he served as the Head Tax Counsel at CVS Health.