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Initial impressions of proposed regulations: Opportunity zones and deferral of gains

U.S. opportunity zones and deferral of gains

KPMG LLP today provides a report of initial impressions about the proposed regulations (REG-115420-18) that the U.S. Treasury Department and IRS released on October 19, 2018, along with a revenue ruling as guidance under section 1400Z-2—the opportunity zone measures added to the Code by the new U.S. tax law.


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Read today's discussion of initial impressions: KPMG report: New rules for opportunity zones [PDF 1.3 MB]


Section 1400Z-2 relates to gains that may be deferred as a result of a taxpayer’s investment in a qualified opportunity fund (QOF), and was added to the Code by the new tax law (Pub. L. No. 115-97 enacted December 22, 2017). 


  • Read text of the proposed regulations [PDF 239 KB] (74 pages) 
  • Read Rev. Rul. 2018-29 [PDF 41 KB] providing guidance for taxpayers on the “original use” requirement for land purchased after 2017 in qualified opportunity zones
  • Read the draft version of Form 8996 [PDF 105 KB] and the related draft instructions [PDF 208 KB] to be used by investment vehicles to self-certify as qualified opportunity funds

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