The IRS published proposed rules on April 14 setting forth requirements that certain foreign persons and foreign-owned partnerships would have to meet to elect the tax benefits related to investing in qualified opportunity funds. The rules would also allow for the reduction or elimination of withholding taxes on transfers that give rise to gain that is deferred under the qualified opportunity fund provisions.
In addition, to address concerns related to the Covid-19 pandemic, the proposed rules would give opportunity zone businesses more flexibility with respect to working capital safe harbor plans.
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