It moves certain compliance deadlines to July 15. It is mildly useful, but many working groups have already lobbied for further extensions.
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How does the newly issued notice by IRS on April 9 impact the OZ initiative for people impacted by the Covid-19?
How does it offer relief for OZ investors?
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The IRS' Notice 2020-23<https://www.irs.gov/pub/irs-drop/n-20-23.pdf> provides certain taxpayers with additional time to invest“eligible gain” into a qualified opportunity fund (“QOF”). The IRS Notice provides that any person performing certain time-sensitive actions due to be performed on or after April 1, 2020, and before July 15, 2020 (“Specified Time-Sensitive Action”), is entitled to an extension of the deadline to July 15, 2020. The IRS Notice deems the 180-day investment period into a QOF is deemed a Specified Time-Sensitive Action thus if a taxpayer’s 180-day period for investing gain into a QOF falls on or after April 1, 2020, and before July 15, 2020, the taxpayer’s investment window is extended to July 15, 2020. The IRS Notice can provide QOFs with additional time to meet their deadlines of having 90% of its assets held in qualified opportunity zone property. The 90% test is determined on the last day of the first six-month period of the QOF’s tax year and the last day of the QOF’s tax year. A QOF can disregard cash received in the previous six months if certain requirements are met.
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