Sadis Opportunity Zone Practice Group Submits a Comment Letter to the Department of Treasury and IRS Regarding Proposed Regulations

The Sadis Opportunity Zone Practice Group recently submitted a comment letter on to the Department of Treasury and the Internal Revenue Service (IRS), commenting on issues raised by the Department of Treasury’s proposed regulations for Opportunity Zones. For a summary of the proposed regulations, please see our October Alert. The comment letter seeks further clarifications on key aspects of the Opportunity Zone regime, including:

  • the application of the original use test to land in rural contexts,

  • how the substantial improvement test will be applied to rural industries such timber, agriculture and mining, and

  • the types of improvements to and upon land that will qualify as eligible investments under the Opportunity Zone program.

Further guidance and clarification on the October 2018 guidelines is expected soon by the Department of Treasury. For the full letter, please click below.

Please contact Richard Shamos (212) 573‐8027 or Alex Gelinas (212) 573‐8159 with any questions about this letter or any other Opportunity Zones matter.