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 Lawrence H. Brenman Lawrence H. Brenman

An experienced tax and business lawyer, Lawrence H. Brenman assists clients in structuring and negotiating real estate private equity funds, Qualified Opportunity Zone (QOZ) Funds, mergers and acquisitions, joint ventures, limited partnerships, and limited liability companies. Larry has helped structure and carry out

An experienced tax and business lawyer, Lawrence H. Brenman assists clients in structuring and negotiating real estate private equity funds, Qualified Opportunity Zone (QOZ) Funds, mergers and acquisitions, joint ventures, limited partnerships, and limited liability companies. Larry has helped structure and carry out tax planning for private equity investments, including the use of blocker structures and private REITs for cross-border and tax-exempt investors. He is experienced in tax planning for businesses, real estate development and syndication.

Larry counsels business owners on a wide range of issues, including business entity structuring, capitalization of the business, compensation of its executives, buy-sell arrangements, and day-to-day contractual matters such as leasing, licensing, and purchase and sale contracts.

Larry is a certified public accountant and an adjunct professor at Chicago-Kent College of Law. He has lectured on a wide variety of transactional law topics, including the tax aspects of partnerships, limited liability companies and real estate investments, the passive activity rules and tax planning for corporate acquisitions.

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.

Photo of Brian Gaudet 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.

Brian regularly writes on issues related to his tax practice, including IRS Source-of-Income Rules and Business Interest Deduction Limitations for Health Care Entities.