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The Department of Treasury solicited comments as part of the process for the proposed rule “Investing in Qualified Opportunity Funds, IRS REG-115420-18.” As the IRS considers revisions to Form 8996, Brett Theodos and Brady Meixell recommend they consider including additional Fund- and transaction-level reporting requirements. Following precedent from prior economic development incentives and programs, nonburdensome reporting requirements would answer questions of “who,” “what,” “when,” “where,” and “how much” for each Opportunity Zones investment. Without collecting this basic information, it will be difficult for IRS to fulfill its statutory evaluation obligations for Opportunity Zones.