It’s been one week since the IRS released the second tranche of regulatory guidance on Qualified Opportunity Funds. This guidance is a huge step in the right direction in terms of clarifying the biggest questions that OZ participants had following the first tranche of proposed rules. And it goes a long way toward finally clearing the way for Opportunity Zone business investment.
In the week since the new regulations have been released, several analyses of the 169-page document have been created. Here are the best ones that I’ve found so far.
(Did I miss any good ones? Leave a comment below!)
The Opportunity Zones Podcast
In this special Monday morning edition of the podcast, Tony and I break down the 10 biggest questions that the second tranche answered, a few surprises, and the biggest issues still outstanding.
Economic Innovation Group
EIG summarizes the key issues, including timing flexibility at the fund level, gross income test, interim gains, substantial improvement for business, working capital safe harbor, valuation methods, vacant property, “substantially all,” leased property, and more.
Tax codehead Tony Nitti takes a deep dive into the second tranche in the context of the statute and the first tranche. Warning: this very thorough 12,000-word breakdown is not for the faint of heart!
New York Times
Jim Tankersley offers a good high-level overview of the new regs for the masses, without getting too much in the weeds.
Michael Novogradac provides the key highlights of the second tranche in a two-part blog post and podcast episode. He looks at what the new regs mean for operating businesses, investors, fund operations, and real estate. Plus, a brief look at a few open items.