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ARTICLE · 15 JANUARY 2020

Opportunity Zones: Final Regulations Provide Additional Flexibility

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On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the "Final Regulations") regarding "Qualified Opportunity Zones"

United StatesFinance and Banking
Lisa Brill
Lisa Brill
Derek Kershaw
Derek Kershaw
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On January 13, 2020, the Treasury Department and the Internal Revenue Service published final regulations (the “Final Regulations”) regarding “Qualified Opportunity Zones” (“QOZs”) and “Qualified Opportunity Funds” formed to invest in QOZs (“QOFs”). The first set of proposed regulations, released on October 19, 2018, contained helpful guidance but left numerous lingering issues and unanswered questions.[1] A second set of proposed regulations, released on April 17, 2019 (together with the first set of proposed regulations, the “Proposed Regulations”), provided relief to QOFs and their investors and clarified the manner in which QOFs may be structured.[2] The Final Regulations largely adopt the Proposed Regulations; most of the changes and additions made by the Final Regulations are clarifying in nature. A few of the changes, however, are significantly favorable to investors, which reflects the government’s continuing commitment to facilitate broad investment in QOFs

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