Morris Manning & Martin, LLP

Treasury Answers Gatekeeping Questions on Qualified Opportunity Zone Program


On Friday, October 19, 2018, the Internal Revenue Service released highly anticipated guidance answering some of the many questions regarding the Qualified Opportunity Zone Program (the OZ Program) of Code Sections 1400Z-1 and 1400Z-2. The guidance was published in the form of:

(i) The first round of proposed Treasury Regulations (the “Regulations”),

(ii) a Revenue Ruling addressing the “original use” requirement and the “substantial improvement” test,

(iii) drafts of the Qualified Opportunity Fund (OZ Fund) self-certification form, IRS Form 8996, and its instructions, and

(iv) updates to the Internal Revenue Service’s (IRS) Frequently Asked Questions webpage (the FAQ Webpage)

We have compiled a framework of the relevant questions addressed in the guidance and the Treasury Department’s responses, click to download: