Avoiding Disguised Sales in Qualified Opportunity Funds: Critical Tax Considerations for QOF Investments
Recent IRS Regulations, Application of Section 707, Exceptions, Assumption of Liabilities, Debt Financed Transfer Considerations
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE course will provide tax professionals an in-depth analysis of qualified opportunity funds (QOFs), specifically focusing on recent IRS regulations and partnership disguised sales. The panel will discuss current IRS regulations on the application of disguised sale rules to investments in QOFs and qualified opportunity zone businesses (QOZBs), debt-financed distributions, and other related topics.
- Overview of QOZ program
- Application of disguised sale rules to QOF investments
- Allocation of partnership liabilities
- Debt financed distributions
- Application of disguised sale rules to QOF investments in QOZBs
- Secondary acquisitions of QOF interests
The panel will discuss these and other key issues:
- What are the key tax considerations for making a QOF investment?
- What are the key tax considerations for investors holding QOF investments?
- What are the key provisions of recent IRS regulations regarding QOF investments?
- What impact does the application of disguised sale rules have on QOF investments?
Gene Crick, Jr.
Nelson Mullins Riley & Scarborough
Mr. Crick handles income tax isses and transactional legal work with respect to the buying and selling of entities or... | Read More
Mr. Crick handles income tax isses and transactional legal work with respect to the buying and selling of entities or assets for various business clients. His transaction and tax experience includes affordable housing, historic buildings, and commercial buildings qualifying for federal income tax credits. Mr. Crick also has experience setting up qualified opportunity funds and qualified opportunity zone businesses.Close
Shearman & Sterling
Mr. Kershaw is counsel in the Tax practice. He advises clients on a range of areas of tax law. His practice includes... | Read More
Mr. Kershaw is counsel in the Tax practice. He advises clients on a range of areas of tax law. His practice includes domestic and international transactional work, including mergers and acquisitions, joint ventures, private equity and hedge fund investments and structuring, REITs and other pass-through entities, and real estate.Close