Qualified Opportunity Zones and Tax Credits: IRS regulations, capital gain deferral mechanisms, section 1400Z
Michael Sanders is the lead partner of the Firm’s Washington, D.C., office tax group. He focuses his practice in the area of taxation, offering particular knowledge in matters affecting partnerships, limited liability companies, S-corporations, real estate, tax controversy, opportunity zone funds, and estate planning, including trusts and estates.
Mr. Goldie is one of the leaders of Plante Moran's housing and community development solutions group.
On-Demand:June 24, 2022
$195.002 hour CLE
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The Qualified Opportunity Zone program encourages economic growth in distressed communities and subsidizes growing businesses, through capital gain deferrals and exclusion from gross income on investments held for at least 10 years. The program’s success has exceeded the anticipated projections when enacted in 2017. Although the Treasury Regulations are quite extensive and raise numerous technical issues, various planning techniques have been developed which enable individuals and businesses to take advantage of the incentive to invest capital and raise funds in a syndicated model.
Key topics to be discussed:
Legislative Outlook: OZ Transparency, Extension and Improvement Act
Comparison of Section 1031 versus OZ Tax Benefits
Navigate Working Capital Safe Harbor and other open issues
Potential foot-faults and traps for the unwar
Date / Time: June 24, 2022
Michael Sanders | BlankRome
Michael Sanders is the lead partner of the Firm’s Washington, D.C., office tax group. He focuses his practice in the area of taxation, offering particular knowledge in matters affecting partnerships, limited liability companies, S-corporations, real estate, tax controversy, opportunity zone funds, and estate planning, including trusts and estates. He also has a large practice in the area of exempt organizations involving healthcare and low-income housing, associations and joint ventures between for-profits and nonprofits, as well as structuring New Markets Tax Credit (“NMTC”) and Historic Tax Credit (“HTC”) transactions. He regularly serves as an expert witness in complex litigation.
Michael is the author of Joint Ventures Involving Tax-Exempt Organizations (4th Ed., 2013; 2016 Supplement) published by John Wiley & Sons, Inc. The book was recently cited by the majority opinion in the widely covered U.S. Supreme Court decision in Burwell v. Hobby Lobby Stores, Inc. He is also an adjunct professor at George Washington University Law Center and Georgetown University Law School teaching Income Taxation of Partnerships and Subchapter S Corporations and Tax Treatment of Charities and Other Non-Profit Organizations, and Joint Ventures Involving Tax Exempt Organizations (including healthcare, universities, LIHTC, new markets, HTC, and conservation organizations, respectively).
Michael is a frequent speaker on the Opportunity Zone Fund legislation, part of the 2017 Tax Cut and Jobs Act. He advises funds, investors, and real estate companies on the program requirements and provides up-to-date guidance.
Michael has been recognized by Chambers USA as a leading tax attorney, with clients noting that “he stands out for his persistence, accessibility, seasoned judgment and reasonableness, coupled with his creativity in finding solutions” and blankrome.com that he is “well connected in the industry, very experienced and bright.” In 2007, he was selected from a field of the nation’s leading lawyers and judges as a finalist for the Lawdragon 500 based upon his current impact on the biggest issues and deals in the law.
Prior to Blank Rome, Michael served as an attorney-adviser to the assistant secretary of tax policy at the Office of Tax Legislative Counsel and as a trial attorney at the U.S. Department of Justice (Attorney General’s Honors Program).
In 2016, Michael was honored by The George Washington University Law School for his 40 years of teaching at the law school.
Gordon Goldie | Plante Moran
Mr. Goldie is one of the leaders of Plante Moran’s housing and community development solutions group. He spends 100 percent of his time assisting for-profit and not-for-profit clients with real estate development projects involving tax incentives such as historic tax credits, New Markets Tax Credits (NMTCs), Brownfield redevelopment incentives, and the new opportunity zones incentive. Mr. Goldie assists clients nationwide in identifying available tax incentives and structuring transactions to optimize the net benefit of these incentives while ensuring compliance with all applicable tax law requirements.
I. Opportunity Zone Structure and Benefits including Working Capital Safe Harbor and other open issues | 2:00pm – 2:30pm
II. Legislative Outlook: OZ Transparency, Extension, and Improvement | 2:30pm – 2:40pm
III. Comparison of Section 1031 vs. OZ tax benefits | 2:40pm – 2:55pm
IV. Q&A | 2:55pm – 3:00pm
Break | 3:00pm – 3:10pm
V. Potential foot faults and traps for the unwary | 3:10pm – 3:40pm
VI. Best practices | 3:40pm – 4:05pm VII. Q&A | 4:05pm – 4:10pm