On Friday, October 19, 2018, the Internal Revenue Service released highly anticipated guidance answering some of the many questions regarding the Qualified Opportunity Zone Program (the OZ Program) of Code Sections 1400Z-1 and 1400Z-2. The guidance was published in the form of:
(i) The first round of proposed Treasury Regulations (the “Regulations”),
(ii) a Revenue Ruling addressing the “original use” requirement and the “substantial improvement” test,
(iii) drafts of the Qualified Opportunity Fund (OZ Fund) self-certification form, IRS Form 8996, and its instructions, and
(iv) updates to the Internal Revenue Service’s (IRS) Frequently Asked Questions webpage (the FAQ Webpage)
We have compiled a framework of the relevant questions addressed in the guidance and the Treasury Department’s responses, click to download:
