In the Headlines
November 7, 2018

Basis and Allocation Issues Raised in Opportunity Zone


Partner Nicole Elliott discussed several questions that have come from the Opportunity Zone Program as new proposed regulations need to be clarified. Ms. Elliott explains that for an Opportunity Zone business to qualify, the business must receive 50 percent of its income from active conduct, but there is no clear definition as to what active conduct entails. Another issue, such as how to value a tangible property if there are no financial statements or cost basis, has not yet been determined. New proposed regulations are expected to be released by the end of 2018, and several hope that they will clarify the rules more.

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