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On April 17, 2019, the US Internal Revenue Service (IRS) released a second set of proposed regulations providing guidance on structuring qualified opportunity funds (“QOFs”). QOF transactions allow investors to defer recognized capital gains until 2026 and can provide tax-advantaged returns on investments made in Qualified Opportunity Zones. The new regulations address many issues left open by the initial set of proposed regulations released in October 2018. We expect that the guidance provided by the new proposed regulations will encourage market participants to accelerate QOF offerings. Mark Leeds, Matthew McDonald and JoonBeom Pae, tax partners with Mayer Brown’s New York and Chicago offices, analyze the new proposed regulations in the attached Legal Update.
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