United States Government Publishing Office publisher pbl distributor dst United States National Archives and Records Administration Office of the Federal Register author aut Government Organization text government publication eng FR Regulatory Information 2020_register executive 2020-01-11 article Part II Rules and Regulations D09002ee1c7b84760 D09002ee1c7b847e5 United States Department of the Treasury originator org United States Government Agency or Subagency United States Internal Revenue Service originator org United States Government Agency or Subagency This document contains final regulations governing the extent to which taxpayers may elect the Federal income tax benefits provided by section 1400Z-2 of the Internal Revenue Code (Code) with respect to certain equity interests in a qualified opportunity fund (QOF). The final regulations address the comments received in response to the two notices of proposed rulemaking issued under section 1400Z-2 and provide additional guidance for taxpayers eligible to elect to temporarily defer the inclusion in gross income of certain gains if corresponding amounts are invested in certain equity interests in QOFs, as well as guidance on the ability of such taxpayers to exclude from gross income additional gain recognized after holding those equity interests for at least 10 years. The final regulations also address various requirements that must be met for an entity to qualify as a QOF, including requirements that must be met for an entity to qualify as a qualified opportunity zone business. The final regulations affect entities that self-certify as QOFs and eligible taxpayers that make investments, whether qualifying or non-qualifying, in such entities. 85 FR 1866 https://www.govinfo.gov/app/details/FR-2020-01-13/2019-27846 2019-27846 fr13ja20-10 RIN 1545-BP04 4830-01-P TD 9889 https://www.govinfo.gov/app/details/FR-2020-01-13/2019-27846 https://www.govinfo.gov/content/pkg/FR-2020-01-13/html/2019-27846.htm https://www.govinfo.gov/content/pkg/FR-2020-01-13/pdf/2019-27846.pdf Income Taxes Reporting and Recordkeeping Requirements 136 p. 1866 2001 85 FR 1866 Title 26 Part 1 26 CFR Part 1 RIN 1545-BP04 Investing in Qualified Opportunity Funds; Federal Register Vol. 85, Issue RULE 2019-27846 II DEPARTMENT OF THE TREASURY Internal Revenue Service 2020-03-13 TD 9889 4830-01-P 2019-27846 Final regulation.

This document contains final regulations governing the extent to which taxpayers may elect the Federal income tax benefits provided by section 1400Z-2 of the Internal Revenue Code (Code) with respect to certain equity interests in a qualified opportunity fund (QOF). The final regulations address the comments received in response to the two notices of proposed rulemaking issued under section 1400Z-2 and provide additional guidance for taxpayers eligible to elect to temporarily defer the inclusion in gross income of certain gains if corresponding amounts are invested in certain equity interests in QOFs, as well as guidance on the ability of such taxpayers to exclude from gross income additional gain recognized after holding those equity interests for at least 10 years. The final regulations also address various requirements that must be met for an entity to qualify as a QOF, including requirements that must be met for an entity to qualify as a qualified opportunity zone business. The final regulations affect entities that self-certify as QOFs and eligible taxpayers that make investments, whether qualifying or non-qualifying, in such entities.

Effective date: The final regulations contained in this document are effective on March 13, 2020. Concerning section 1400Z-2 and these regulations generally, Alfred H. Bae, (202) 317-7006, or Kyle C. Griffin, (202) 317-4718, of the Office of Associate Chief Counsel (Income Tax and Accounting); concerning issues related to C corporations and consolidated groups, Jeremy Aron-Dine, (202) 317-6848, or Sarah Hoyt, (202) 317-5024, of the Office of Associate Chief Counsel (Corporate); concerning issues related to gains from financial contracts, REITs, or RICs, Andrea Hoffenson or Pamela Lew, (202) 317- 7053, of the Office of Associate Chief Counsel (Financial Institutions and Products); concerning issues related to investments by foreign persons, Eric Florenz, (202) 317-6941, or Milton Cahn (202) 317-6937, of the Office of Associate Chief Counsel (International); concerning issues related to partnerships, S corporations or trusts, Marla Borkson, Sonia Kothari, or Vishal Amin, at (202) 317-6850, and concerning issues related to estates and gifts, Leslie Finlow or Lorraine Gardner, at (202) 317-6859, of the Office of Associate Chief Counsel (Passthroughs and Special Industries). These numbers are not toll-free numbers. Income Taxes Reporting and Recordkeeping Requirements Investing in Qualified Opportunity Funds, http://www.irs.gov www.regulations.gov Vol. 85, no. 8 Office of the Federal Register, National Archives and Records Administration 2020-01-13 continuing daily deposited born digital 279 p. Table of Contents: AE 2.7: GS 4.107: AE 2.106: KF70.A2 https://www.govinfo.gov/app/details/FR-2020-01-13 P0b002ee1a49a32fa 0097-6326 0042-1219 0364-1406 769-004-00000-9 000582072 f:fr13ja20 https://www.govinfo.gov/app/details/FR-2020-01-13 https://www.govinfo.gov/content/pkg/FR-2020-01-13/pdf/FR-2020-01-13.pdf https://www.govinfo.gov/content/pkg/FR-2020-01-13/xml/FR-2020-01-13.xml fdlp 1731 2001 DGPO 2020-01-11 2024-05-30 FR-2020-01-13 machine generated eng FR FR-2020-01-13 85 8