On October 19, 2018, the US Internal Revenue Service released initial guidance on the Qualified Opportunity Fund (QOF) rules. The QOF rules allow US taxpayers to defer capital gain taxation by investing an amount equal to the gain in a QOF within 180 days of the gain recognition event. While not answering every question, the initial set of rules provides a working roadmap for implementing QOF transactions. Mark Leeds, David Burton, Zal Kumar and Maria Carolina Grecco, all tax practitioners in the New York office of Mayer Brown, provide an overview of the new rules in the attached Legal Update.
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