Investing in Qualified Opportunity Funds; Correcting Amendments

As Enacted ( Federal Register)

Cited in

Published date	06 April 2020
Citation	85 FR 19082
Record Number	2020-07013
Section	Rules and Regulations
Court	Internal Revenue Service

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Federal Register / Vol. 85, No. 66 / Monday, April 6, 2020 / Rules and Regulations

before further flight, remove from service the

RH rear fitting and its bolts.

(ii) For any RH rear fitting that has

accumulated less than 1,470 total hours TIS,

remove from service the RH rear fitting and

its bolts before the fitting accumulates 1,470

total hours TIS.

(iii) For any LH rear fitting that has

accumulated 13,600 or more total hours TIS,

before further flight, remove from service the

LH rear fitting and its bolts.

(iv) For any LH rear fitting that has

accumulated less than 13,600 total hours TIS:

(A) If a Major Inspection ‘‘G’’ has not been

completed since the LH rear fitting has been

installed, remove from service the LH rear

bolts during the next Major Inspection ‘‘G’’

inspection; or

Note 1 to paragraph (e)(1)(iv)(A) of this AD:

Major Inspection ‘‘G’’ (7,500 hours TIS

between overhauls) is defined in

Maintenance Manual MET 05–29–00–601.

(B) If a Major Inspection ‘‘G’’ has been

completed since the LH rear fitting has been

installed, before further flight, remove from

service the LH rear bolts; and

before the fitting accumulates 13,600 total

hours TIS.

(2) Thereafter following paragraph (e)(1) of

this AD, remove from service any RH rear

fitting and its bolts at intervals not to exceed

1,470 hours TIS, remove from service any LH

rear fitting at intervals not to exceed 13,600

hours TIS, and remove from service any LH

rear bolts during each Major Inspection ‘‘G.’’

(3) During the next Major Inspection ‘‘G,’’

remove from service the MGB suspension bar

front bolts. Thereafter, remove from service

the front bolts during each Major Inspection

‘‘G.’’

(f) Alternative Methods of Compliance

(AMOCs)

(1) The Manager, Safety Management

Section, Rotorcraft Standards Branch, FAA,

may approve AMOCs for this AD. Send your

proposal to: Matt Fuller, Senior Aviation

Safety Engineer, Safety Management Section,

Rotorcraft Standards Branch, FAA, 10101

Hillwood Pkwy., Fort Worth, TX 76177;

telephone 817–222–5110; email 9-ASW-FTW-

AMOC-Requests@faa.gov.

(2) For operations conducted under a 14

CFR part 119 operating certificate or under

14 CFR part 91, subpart K, the FAA suggests

that you notify your principal inspector, or

lacking a principal inspector, the manager of

the local flight standards district office or

certificate holding district office, before

operating any aircraft complying with this

AD through an AMOC.

(g) Additional Information

(1) Airbus Helicopters Alert Service

Bulletin No. AS332–01.00.90, Revision 0,

dated November 21, 2018, which is not

incorporated by reference, contains

additional information about the subject of

this AD. For service information identified in

this AD, contact Airbus Helicopters, 2701 N

Forum Drive, Grand Prairie, TX 75052;

telephone 972–641–0000 or 800–232–0323;

fax 972–641–3775; or at https://

www.airbus.com/helicopters/services/

technical-support.html. You may view the

referenced service information at the FAA,

Office of the Regional Counsel, Southwest

Region, 10101 Hillwood Pkwy., Room 6N–

321, Fort Worth, TX 76177.

(2) The subject of this AD is addressed in

European Union Aviation Safety Agency

(previously European Aviation Safety

Agency) (EASA) AD No. 2018–0260, dated

December 3, 2018. You may view the EASA

AD on the internet at https://

www.regulations.gov in Docket No. FAA–

2019–1015.

(h) Subject

Joint Aircraft Service Component (JASC)

Code: 6320 Main Rotor Gearbox.

Issued on March 27, 2020.

Lance T. Gant,

Director, Compliance & Airworthiness

Division, Aircraft Certification Service.

[FR Doc. 2020–07138 Filed 4–3–20; 8:45 am]

BILLING CODE 4910–13–P

DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Part 1

[TD 9889]

RIN 1545–BO4

Investing in Qualified Opportunity

Funds; Correcting Amendments

AGENCY

: Internal Revenue Service (IRS),

Treasury.

ACTION

: Correcting amendments.

SUMMARY

: This document contains

corrections to Treasury Decision 9889,

which was published in the Federal

Treasury Decision 9889 contained final

regulations under the Internal Revenue

Code (the ‘‘Code) that govern the extent

to which taxpayers may elect the

Federal income tax benefits with respect

to certain equity interests in a qualified

opportunity fund (QOF).

DATES

: These corrections are effective

on April 1, 2020, and applicable as of

January 13, 2020.

FOR FURTHER INFORMATION CONTACT

Concerning section 1400Z–2 and these

regulations generally, Alfred H. Bae,

(202) 317–7006, or Kyle C. Griffin, (202)

317–4718, of the Office of Associate

Chief Counsel (Income Tax and

Accounting); concerning issues related

to C corporations and consolidated

groups, Jeremy Aron-Dine, (202) 317–

6848, or Sarah Hoyt, (202) 317–5024, of

the Office of Associate Chief Counsel

(Corporate); concerning issues related to

gains from financial contracts, REITs, or

RICs, Andrea Hoffenson or Pamela Lew,

(202) 317–7053, of the Office of

Associate Chief Counsel (Financial

Institutions and Products); concerning

issues related to investments by foreign

persons, Eric Florenz, (202) 317–6941,

or Milton Cahn (202) 317–6937, of the

Office of Associate Chief Counsel

(International); concerning issues

related to partnerships, S corporations

or trusts, Marla Borkson, Sonia Kothari,

or Vishal Amin, at (202) 317–6850, and

concerning issues related to estates and

gifts, Leslie Finlow or Lorraine Gardner,

at (202) 317–6859, of the Office of

Associate Chief Counsel (Passthroughs

and Special Industries). These numbers

are not toll-free numbers.

SUPPLEMENTARY INFORMATION

Background

The final regulations (TD 9889) that

are the subject of this correction are

under section 1400Z–2 of the Code.

Need for Correction

As published on January 13, 2020 (85

FR 1866) contained errors that may

prove to be misleading and need to be

corrected.

List of Subjects in 26 CFR Part 1

Income taxes, Reporting and

recordkeeping requirements.

Correction of Publication

Accordingly, 26 CFR part 1 is

corrected by making the following

correcting amendments:

PART 1—INCOME TAXES

■Paragraph 1. The authority citation

continues to read in part as follows:

Authority: 26 U.S.C. 7805 * * *

■Par. 2. Section1.1400Z2–0 is

amended:

■a. By revising the entry for

§ 1.1400Z2(a)–1(d)(2);

■b. In the entry for § 1.1400Z2(b)–1(h)

introductory text, by removing the

language ‘‘S corporations’’; and

■c. By revising the entry for

§ 1.1400Z2(d)–1(a)(4).

The revisions read as follows:

§ 1.1400Z2–0 Table of Contents.

* * * * *

§1.1400Z2(a)–1 Deferring tax on

capital gains by investing in opportunity

zones.

* * * * *

(d) * * *

(2) Annual reporting of qualifying

investments.

* * * * *

§1.1400Z2(d)–1 Qualified

opportunity funds and qualified

opportunity zone businesses.

(a) * * *

(4) [Reserved]

* * * * *

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■Par. 3. Section 1.1400Z2(a)–1 is

amended:

■a. In paragraph (b)(3) by adding the

language ‘‘described in § 1.1400Z2(d)–

2(d)(4)(ii) that is’’ after the words

‘‘means the test’’;

■b. In the last sentence of paragraph

(b)(11)(ix)(A)(2), by removing the

language ‘‘publications’’ and adding in

its place ‘‘instructions’’;

■c. In paragraph (b)(32), by removing

the word ‘‘business’’;

■d. In the last sentence of paragraph

(c)(1)(iii)(A), by removing the word

‘‘only’’ before ‘‘apply’’; and

■e. By revising paragraphs (d)(2), (g)(2)

introductory text, and (g)(2)(i).

The revisions read as follows:

§ 1.1400Z2(a)–1 Deferring tax on capital

gains by investing in opportunity zones.

* * * * *

(d) * * *

(2) Annual reporting of qualifying

investments. An eligible taxpayer must

report any qualifying investment held at

any point during the taxable year in

accordance with guidance published in

the Internal Revenue Bulletin or in

forms and instructions (see

§§ 601.601(d)(2) and 601.602 of this

chapter). A failure to make this report

for any given taxable year will result in

a rebuttable presumption that the

taxpayer has had an inclusion event

described in § 1.1400Z2(b)–1(c) during

that year. The presumption described in

the previous sentence may be rebutted

by the taxpayer making the report

described in the first sentence of this

paragraph (d)(2) or by the taxpayer

establishing to the satisfaction of the

Commissioner that an inclusion event

described in § 1.1400Z2(b)–1(c) did not

occur during that taxable year.

* * * * *

(g) * * *

(2) Prior periods. With respect to

eligible gains that would be recognized

(absent the making of a deferral

election) during the portion of a

taxpayer’s first taxable year ending after

December 21, 2017, and during taxable

years beginning after December 21,

2017, and on or before March 13, 2020,

a taxpayer may choose either—

(i) To apply the section 1400Z–2

regulations, if applied in a consistent

manner for all such taxable years

(reliance by a taxpayer under paragraph

(g)(2)(ii) of this section, § 1.1400Z2(b)–

1(j)(2)(ii), § 1.1400Z2(d)–1(e)(2)(ii),

§ 1.1400Z2(d)–2(e)(2)(ii), or

§ 1.1400Z2(f)–1(d)(2)(ii), is disregarded

solely for purposes of the consistency

requirement under this paragraph

(g)(2)(i)); or

* * * * *

■Par. 4. Section 1.1400Z2(b)–1 is

amended:

■a. In the last sentence of paragraph

(c)(6)(ii)(B), by removing ‘‘§ 1400Z2(c)–

1(b)(1)(ii)’’ and adding in its place

‘‘§ 1.1400Z2(c)–1(b)(1)(ii)’’; and

■b. By revising paragraphs (j)(2)

introductory text and (j)(2)(i).

The revisions read as follows:

§ 1.1400Z2(b)–1 Inclusion of gains that

have been deferred under section 1400Z–

2(a)

* * * * *

(j) * * *

(2) Prior periods. With respect to the

portion of a taxpayer’s first taxable year

ending after December 21, 2017, and for

taxable years beginning after December

21, 2017, and on or before March 13,

2020, a taxpayer may choose either—

To apply the section 1400Z–2

regulations, if applied in a consistent

manner for all such taxable years

(reliance by a taxpayer on paragraph

(j)(2)(ii) of this section, § 1.1400Z2(a)–

1(g)(2)(ii), § 1.1400Z2(d)–1(e)(2)(ii),

§ 1.1400Z2(d)–2(e)(2)(ii), or

§ 1.1400Z2(f)–1(d)(2)(ii), is disregarded

solely for purposes of the consistency

requirement under this paragraph

(j)(2)(i)); or

* * * * *

§ 1.1400Z2(c)–1 [Amended]

■Par. 5. Section 1.1400Z2(c)–1 is

amended:

■a. In the first sentence of paragraph

(b)(2)(ii)(A), by removing the language

‘‘one of more partnerships’’ and adding

in its place ‘‘one or more partnerships’’;

and

■b. In the third sentence of paragraph

(b)(2)(ii)(B)(1), by removing

‘‘§ 1400Z2(b)–1(c)(6)(iv)(B)’’ and adding

in its place ‘‘§ 1.1400Z2(b)–

1(c)(6)(iv)(B)’’.

■Par. 6. Section 1.1400Z2(d)–1 is

amended:

■a. In the first sentence of paragraph

(b)(2)(i)(C)(2)(ii), by removing the

language ‘‘not later than’’ and adding in

its place ‘‘not earlier than’’;

■b. By revising paragraph (b)(4)(ii);

■c. In the first sentence of paragraph

(c)(2)(i)(C)(2), by removing the language

‘‘is made by’’ and adding in its place

‘‘may be made by’’;

■d. In paragraph (d)(3)(v)(D), by

removing the language ‘‘receive up to’’

and adding in its place ‘‘receive not

more than’’;

■e. By removing paragraphs (d)(3)(v)(F)

and (G);

■f. By revising paragraphs (d)(3)(vi) and

(vii);

■g. By redesignating paragraphs

(d)(3)(ix) and (x) as (d)(3)(viii) and (ix),

respectively; and

■h. By revising paragraphs (d)(6)(i) and

(iii), (e)(2) introductory text, and

(e)(2)(i).

The revisions read as follows:

§ 1.1400Z2(d)–1 Qualified opportunity

funds and qualified opportunity zone

businesses.

* * * * *

(b) * * *

(4) * * *

(ii) Property owned by an eligible

entity—(A) Property purchased or

constructed. The value of each property

owned by an eligible entity that is

acquired by purchase for fair market

value or constructed for fair market

value is the eligible entity’s unadjusted

cost basis of the asset under section

1012 or section 1013. Solely for

purposes of this paragraph (b)(4)(ii)(A),

the acquisition by a QOF of qualified

opportunity zone stock or a qualified

opportunity zone partnership interest is

treated as a purchase of such interest by

the QOF.

* * * * *

(d) * * *

(3) * * *

(vi) Safe harbor for section 1397C

requirements other than ‘‘sin business’’

prohibition—(A) Maximum 62-month

safe harbor for start-up businesses.

Property described in paragraphs

(d)(3)(vi)(B), (C), and (D) of this section

may benefit from one or more 31-month

periods, for a total of 62 months, in the

form of multiple overlapping or a

sequential application of the working

capital safe harbor if—

(1) Each application independently

satisfies all of the requirements in

paragraphs (d)(3)(v)(A) through (C) of

this section;

(2) The working capital assets from an

expiring 31-month period were

expended in accordance with the

requirements in paragraphs (d)(3)(v)(A)

through (C) of this section;

(3) The subsequent infusions of

working capital assets form an integral

part of the plan covered by the initial

working capital safe harbor period; and

(4) Each overlapping or sequential

application of the working capital safe

harbor includes a substantial amount of

working capital assets (which may

include debt instruments described in

section 1221(a)(4)).

(B) Safe harbor for gross income

derived from the active conduct of

business. Solely for purposes of

applying the 50-percent test in section

1397C(b)(2) to the definition of a

qualified opportunity zone business in

section 1400Z–2(d)(3), if any gross

income is derived from property that

paragraph (d)(3)(v) of this section treats

as a reasonable amount of working

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capital, then that gross income is

counted toward satisfaction of the 50-

percent test.

property. Solely for purposes of

applying the use requirement in section

1397C(b)(4) to the definition of a

qualified opportunity zone business

under section 1400Z–2(d)(3), intangible

property purchased or licensed by the

trade or business, pursuant to the

reasonable written plan with a written

schedule for the expenditure of the

working capital, satisfies the use

requirement during any period in which

the business is proceeding in a manner

that is substantially consistent with

paragraphs (d)(3)(v)(A) through (C) of

this section.

(D) Safe harbor for working capital

and property on which working capital

is being expended—(1) Working capital.

If paragraph (d)(3)(v) of this section

treats property of an entity that would

otherwise be nonqualified financial

property as being a reasonable amount

of working capital because of

compliance with the three requirements

of paragraphs (d)(3)(v)(A) through (C) of

this section, the entity satisfies the

requirements of section 1400Z–

2(d)(2)(D)(i) only during the working

capital safe harbor period(s) for which

the requirements of paragraphs

(d)(3)(v)(A) through (C) of this section

are satisfied; however such property is

not qualified opportunity zone business

property for any purpose.

(2) Tangible property acquired with

covered working capital. If tangible

property referred to in paragraph

(d)(3)(v)(A) of this section is expected to

satisfy the requirements of section

1400Z–2(d)(2)(D)(i) as a result of the

planned expenditure of working capital

described in paragraph (d)(3)(v)(A), and

is purchased, leased, or improved by the

trade or business, pursuant to the

written plan for the expenditure of the

working capital, then the tangible

property is treated as qualified

opportunity zone business property

satisfying the requirements of section

1400Z–2(d)(2)(D)(i), during that and

subsequent working capital periods the

property is subject to, for purposes of

the 70-percent tangible property

standard in section 1400Z–2(d)(3).

(vii) Examples. The following

examples illustrate the rules of

paragraphs (d)(3)(v) and (vi) of this

section.

(A) Example 1. General application of

working capital safe harbor—(1) Facts.

QOF F creates a domestic C corporation

E to open a fast-food restaurant and

acquires almost all of the equity of E in

exchange for cash. E has a written plan

and a 20-month schedule for the use of

this cash to establish the restaurant.

Among the planned uses for the cash are

identification of favorable locations in

the qualified opportunity zone, leasing

a building suitable for such a restaurant,

outfitting the building with appropriate

equipment and furniture (both owned

and leased), necessary security deposits,

obtaining a franchise and local permits,

and the hiring and training of kitchen

and wait staff. Not-yet-disbursed

amounts were held in assets described

in section 1397C(e)(1), and these assets

were eventually expended in a manner

consistent with the plan and schedule.

(2) Analysis. E’s use of the cash

qualifies for the working capital safe

harbor described in paragraph (d)(3)(v)

of this section.

(B) Example 2. Multiple applications

of working capital safe harbor—(1)

Facts. QOF G creates a domestic C

corporation H to start a new technology

company and acquires equity of H in

exchange for cash on Date 1. In addition

to H’s rapid deployment of capital

received from other equity investors, H

writes a plan with a 30-month schedule

for the use of the Date 1 cash. The plan

describes use of the cash to research and

develop a new technology (Technology),

including paying salaries for engineers

and other scientists to conduct the

research, purchasing, and leasing

equipment to be used in research and

furnishing office and laboratory space.

Approximately 18 months after Date 1,

on Date 2, G acquires additional equity

in H for cash, and H writes a second

plan. This new plan has a 25-month

schedule for the development of a new

application of existing software

(Application), to be marketed to

government agencies. Among the

planned uses for the cash received on

Date 2 are paying development costs,

including salaries for software

engineers, other employees, and third-

party consultants to assist in developing

and marketing the new application to

the anticipated customers. Not-yet-

disbursed amounts that were scheduled

for development of the Technology and

the Application were held in assets

described in section 1397C(e)(1), and

these assets were eventually expended

in a manner substantially consistent

with the plans and schedules for both

the Technology and the Application.

(2) Analysis. H’s use of both the cash

received on Date 1 and the cash

received on Date 2 qualifies for the

working capital safe harbor described in

paragraph (d)(3)(v) of this section.

working capital safe harbor—(1) Facts.

In 2019, Taxpayer H realized $w million

of capital gains and within the 180-day

period invested $w million in QOF T,

a qualified opportunity fund. QOF T

immediately acquired from partnership

P a partnership interest in P, solely in

exchange for $w million of cash. P

immediately placed the $w million in

working capital assets, which remained

in working capital assets until used. P

had written plans to acquire land in a

qualified opportunity zone on which it

planned to construct a commercial

building. Of the $w million, $x million

was dedicated to the land purchase, $y

million to the construction of the

building, and $z million to ancillary but

necessary expenditures for the project.

The written plans provided for purchase

of the land within a month of receipt of

the cash from QOF T and for the

remaining $y and $z million to be spent

within the next 30 months on

construction of the building and on the

ancillary expenditures. All expenditures

were made on schedule, consuming the

$w million. During the taxable years

that overlap with the first 31-month

period, P had no gross income other

than that derived from the amounts held

in those working capital assets. Prior to

completion of the building, P’s only

assets were the land it purchased, the

unspent amounts in the working capital

assets, and P’s work in process as the

building was constructed.

(2) Analysis—P met the three

requirements of the safe harbor

provided in paragraphs (d)(3)(v)(A)

through (C) of this section. P had a

written plan to spend the $w received

from QOF T for the acquisition,

construction, and/or substantial

improvement of tangible property in a

qualified opportunity zone, as defined

in section 1400Z–1(a). P had a written

schedule consistent with the ordinary

start-up for a business for the

expenditure of the working capital

assets. And, finally, P’s working capital

assets were actually used in a manner

that was substantially consistent with

its written plan and the ordinary start-

up of a business. First, the $x million,

the $y million, and the $z million are

treated as reasonable in amount for

purposes of sections 1397C(b)(2) and

1400Z–2(d)(3)(A)(ii). Second, because P

had no other gross income during the 31

months at issue, 100 percent of P’s gross

income during that time is treated as

derived from an active trade or business

in the qualified opportunity zone for

purposes of satisfying the 50-percent

test of section 1397C(b)(2). Third, for

purposes of satisfying the requirement

of section 1397C(b)(4), during the period

of land acquisition and building

construction a substantial portion of P’s

intangible property is treated as being

used in the active conduct of a trade or

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business in the qualified opportunity

zone. Fourth, all of the facts described

are consistent with QOF T’s interest in

P being a qualified opportunity zone

partnership interest for purposes of

satisfying the 90-percent investment

standard in section 1400Z–2(d)(1).

(3) Analysis if P had purchased an

existing building. The conclusions

would also apply if P’s plans had been

to buy and substantially improve a pre-

existing commercial building. In

addition, the fact that P’s basis in the

building has not yet doubled would not

cause the building to fail to satisfy

section 1400Z–2(d)(2)(D)(i)(III).

(D) Example 4. Multiple applications

of working capital safe harbor to

tangible property—(1) Facts. QOF A

forms a domestic C corporation B to

develop a large mixed-use real estate

development that will consist of

commercial and residential real

property, owning almost all of the

equity of B in exchange for cash. To

raise additional working capital for the

mixed-use real estate development, B

also will borrow cash under a new

revolving credit agreement with an

unrelated lender. B has a master written

plan for the completion of the

commercial and residential real

property over a 55-month period. The

plan provides that the commercial real

property will be completed over a 30

month schedule and subsequently, the

residential real property will be

completed over a 25 month schedule.

The plan further provides that a portion

of the commercial real property is

unable to be used in a trade or business

after the completion of the commercial

real property since that portion of the

commercial real property will be

unusable during the residential

construction phase. Pursuant to B’s

original master plan for the completion

of the real estate development, QOF A

acquires additional equity in B for cash

after the completion of the commercial

development phase, and B commences

use of those working capital assets for

residential development phase.

(2) Analysis. B’s use of the cash for

the commercial and residential phase

qualified for the working capital safe

harbor described in paragraph (d)(3)(v)

of this section. In addition, all of B’s

commercial real property developed

pursuant to B’s original master plan is

treated as qualified opportunity zone

business property under paragraph

(d)(3)(vi)(D) of this section.

* * * * *

(6) * * *

(i) For purposes of the 90-percent

qualified opportunity zone business

holding period requirements set forth in

sections 1400Z–2(d)(2)(B)(i)(III), 1400Z–

2(d)(2)(C)(iii), and 1400Z–

2(d)(2)(D)(i)(III), if a trade or business

causes the QOF to fail the 90-percent

investment standard on a semiannual

testing date, the QOF may treat the stock

or partnership interest in that trade or

business as qualified opportunity zone

property for that semiannual testing

date provided the trade or business

corrects the failure within 6 months of

the date on which the stock or

partnership interest lost its

qualification.

* * * * *

(iii) Each QOF is permitted only one

correction for a trade or business

pursuant to this paragraph (d)(6). If the

entity, at the end of the additional six-

month cure period, fails to qualify as a

qualified opportunity zone business,

then the QOF becomes subject to the

penalty under section 1400Z–2(f)(1) for

each month the entity failed to qualify

as a qualified opportunity zone business

beginning with the first month

following the last month that the QOF

met the 90-percent investment standard.

(e) * * *

(2) Prior periods. With respect to the

portion of a taxpayer’s first taxable year

ending after December 21, 2017, and for

taxable years beginning after December

21, 2017, and on or before March 13,

2020, a taxpayer may choose either—

(i) To apply the section 1400Z–2

regulations, if applied in a consistent

manner for all such taxable years

(reliance by a taxpayer on paragraph

(e)(2)(ii) of this section, § 1.1400Z2(a)–

1(g)(2)(ii), § 1.1400Z2(b)–1(j)(2)(ii),

§ 1.1400Z2(d)–2(e)(2)(ii), or

§ 1.1400Z2(f)–1(d)(2)(ii), is disregarded

solely for purposes of the consistency

requirement under this paragraph

(e)(2)(i)); or

* * * * *

■Par. 7. Section 1.1400Z2(d)–2 is

amended by revising paragraphs (d)(4)(i)

and (ii), (e)(2) introductory text, and

(e)(2)(i) to read as follows:

§ 1.1400Z2(d)–2 Qualified opportunity zone

business property.

* * * * *

(d) * * *

(4) * * *

(i) Qualified tangible property.

Tangible property used in a trade or

business of an eligible entity satisfies

the substantially all requirement of

paragraph (d)(1) of this section if and

only if the tangible property is qualified

tangible property. Qualified tangible

property is tangible property that

satisfies the requirements of paragraph

(d)(4)(ii), (iii) (subject to the limitation

in paragraph (d)(4)(iv) of this section),

or (v) of this section.

(ii) 70-percent use test. Tangible

property held by a trade or business is

qualified tangible property to the extent,

based on the number of days between

two consecutive semiannual testing

dates, not less than 70 percent of the

total utilization of the tangible property

by the trade or business occurs at a

location within the geographic borders

of a qualified opportunity zone (that is,

the 70-percent use test).

* * * * *

(e) * * *

(2) Prior periods. With respect to the

portion of a taxpayer’s first taxable year

ending after December 21, 2017, and for

taxable years beginning after December

21, 2017, and on or before March 13,

2020, a taxpayer may choose either—

(i) To apply the section 1400Z–2

regulations, if applied in a consistent

manner for all such taxable years

(reliance by a taxpayer on paragraph

(e)(2)(ii) of this section, § 1.1400Z2(a)–

1(g)(2)(ii), § 1.1400Z2(b)–1(j)(2)(ii),

§ 1.1400Z2(d)–1(e)(2)(ii), or

§ 1.1400Z2(f)–1(d)(2)(ii), is disregarded

solely for purposes of the consistency

requirement under this paragraph

(e)(2)(i)); or

* * * * *

■Par. 9. Section 1.1400Z2(f)–1 is

amended:

■a. In paragraph (b)(2), by removing the

language ‘‘up to’’ and adding in its place

‘‘not more than’’;

■b. By revising paragraph (c)(3)(iii);

■c. In the first sentence of paragraph

(c)(3)(v)(B), by adding a comma after

‘‘hog and pig farming’’ and removing the

word ‘‘is’’ and adding in its place

‘‘comprise’’; and

■d. By revising paragraphs (d)(2)

introductory text and (d)(2)(i).

The revisions read as follows:

§ 1.1400Z2(f)–1 Administrative rules-

penalties, anti-abuse, etc.

* * * * *

(3) * * *

(iii) Example 3—(A) Facts. Entity C is

a QOF that meets the requirements of

section 1400Z–2(d)(1). Entity C owns

qualified opportunity zone stock in a

domestic corporation described in

section 1400Z–2(d)(2)(B) (Corporation

C), which operates a qualified

opportunity zone business. Entity C also

owns Corporation D stock, which is not

qualified opportunity zone stock, which

stock is less than 10% of the assets of

Entity C. Under section 1400Z–2(e)(2),

these stock holdings cause Entity C to be

related to both Corporation C and

Corporation D. On date 1, under section

1400Z–2(e)(2), Individual S is not a

related person with respect to Entity C,

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19086

Federal Register / Vol. 85, No. 66 / Monday, April 6, 2020 / Rules and Regulations

Corporation C, or Corporation D. On

that date, Individual S sells tangible

property to Corporation C (Asset 1) for

use in Corporation C’s qualified

opportunity zone business and sells a

second asset to Corporation D (Asset 2).

Both items sold were capital assets (as

defined in section 1221), and had an

adjusted basis of $0. As a result,

Individual S realizes gain of $100 from

the sale to Corporation C and $75 from

the sale to Corporation D. At the time of

the sale Individual S has a plan or intent

to invest $175 in Entity C and to make

deferral elections under section 1400Z–

2(a)(1) with respect to the gain from the

two sales. On date 2, for $175 Individual

S acquired an eligible interest in Entity

C, an acquisition that causes Individual

S to become a related person with

respect to Entity C within the meaning

of section 1400Z–2(e)(2). Analysis.

Under paragraph (c)(1) of this section,

Individual S’s $175 gain is not an

eligible gain and cannot be the subject

a deferral election under section 1400Z–

2(a)(1). The gain fails to satisfy

§ 1.1400Z2a–1(b)(11)(i)(C) because of

Individual S’s plan to acquire sufficient

equity in Entity C to become related to

Corporations C and D. Moreover, for the

same reason, the tangible property that

Corporation C purchased from

Individual S fails to satisfy the

requirement that a purchase of qualified

opportunity zone business property

must be from an unrelated person. See

sections 1400Z–2(d)(2)(D)(i)(I) and

179(d)(2)(A).

(B) Circular movement of

consideration. The facts are the same as

in paragraph (c)(3)(iii)(A) of this section

(this Example 3), except that Entity C

contributes the $100 and $75 (received

from Individual S) to Corporations C

and D, respectively, as part of a plan

that includes each transaction described

in paragraph (c)(3)(iii)(A) (collectively,

the transaction series). Under the step

transaction doctrine and circular cash

flow principles, this circular movement

of consideration is disregarded for

Federal income tax purposes, including

for purposes of section 1400Z–2 and the

section 1400Z–2 regulations. Therefore,

the transaction series is treated for

Federal income tax purposes as a

contribution by Individual S of Assets 1

and 2 to Entity C in exchange for an

eligible interest in Entity C, followed by

a contribution by Entity C of Assets 1

and 2 to Corporations C and D,

respectively. This result also would

obtain if Individual S were not related

to Entity C immediately following

Individual S’s acquisition of its eligible

interest from Entity C. See Rev. Rul. 83–

142, 1983–2 C.B. 68; Rev. Rul. 78–397,

1978–2 C.B. 150.

* * * * *

(d) * * *

(2) Prior periods. With respect to the

portion of a taxpayer’s first taxable year

ending after December 21, 2017, that

began on March 13, 2020, a taxpayer

may choose either—

(i) To apply the section 1400Z–2

regulations, if applied in a consistent

manner for all such taxable years

(reliance by a taxpayer on paragraph

(d)(2)(ii) of this section, § 1.1400Z2(a)–

1(g)(2)(ii), § 1.1400Z2(b)–1(j)(2)(ii),

§ 1.1400Z2(d)–1(e)(2)(ii), or

§ 1.1400Z2(d)–2(e)(2)(ii), is disregarded

for purposes of the consistency

requirement under this paragraph

(d)(2)(i)); or

* * * * *

■Par. 10. Section 1.1502–14Z is

amended:

■a. In paragraph (b)(1)(iv)(A), by

removing the language ‘‘the QOF SAG’’

and adding in its place ‘‘a QOF SAG’’;

■b. In the first sentence of paragraph

(b)(1)(iv)(B), by removing the language

‘‘the QOF SAG’’ and adding in its place

‘‘a QOF SAG’’ and removing the

language ‘‘such QOF SAG’’ and adding

in its place ‘‘a single QOF SAG’’;

■c. In paragraph (b)(1)(iv)(C), by

removing the language ‘‘the QOF SAG’’

and adding in its place ‘‘a QOF SAG’’

and removing the language ‘‘such QOF

SAG’’ and adding in its place ‘‘that QOF

SAG’’;

■d. In the first sentence of paragraph

(b)(1)(v), by removing the language ‘‘;

instead, the rules in this paragraph

(b)(1)(v) apply’’ and adding in its place

‘‘. Instead, those investment standard

rules apply’’;

■e. In the first sentence of paragraph

(c)(2)(i), by removing the language ‘‘the

investment’’ and adding in its place ‘‘an

investment’’;

■f. In the fourth sentence of paragraph

(c)(3) introductory text, by removing the

language ‘‘§ 1.1400Z2(b)–1(b)’’ and

adding in its place ‘‘§ 1.1400Z2(a)–

1(a)(1)’’;

■g. By revising the first sentence of

paragraph (f)(2)(i);

■h. In the first sentence of paragraph

(f)(2)(ii)(A), by removing the language

‘‘certain pre-existing QOF subs as QOF

partnerships’’ and adding in its place ‘‘a

pre-existing QOF sub as a QOF

partnership’’;

■i. In the first sentence of paragraph

(f)(2)(ii)(D)(3)(i), by removing the

language ‘‘same as paragraph’’ and

adding in its place ‘‘same as in

paragraph’’;

■j. In paragraph (f)(2)(iii)(A), by

removing the language ‘‘the pre-

existing’’ and adding in its place ‘‘a pre-

existing’’;

■k. In the last sentence of paragraph

(g)(3)(ii), by removing the language

‘‘includable amount’’ and adding in its

place ‘‘amount includable’’;

■l. In the last sentence of paragraph

(h)(3)(iii)(A), by removing the closing

bracket at the end;

■m. In the last sentence of paragraph

(j)(1)(i), by removing the language ‘‘that

results in’’ and adding in its place ‘‘that

result in’’;

■n. In the fourth sentence of paragraph

(j)(3)(ii)(A), by removing the language

‘‘taken into under’’ and adding in its

place ‘‘taken into account under’’; and

■o. By revising paragraph (k)(2)

introductory text.

The revisions read as follows:

§ 1.1502–14Z Application of opportunity

zone rules to members of a consolidated

group.

* * * * *

(f) * * *

(2) * * *

(i) * * * For each pre-existing QOF

sub of a consolidated group, the

consolidated group may make one of the

alternative, irrevocable elections

provided in paragraphs (f)(2)(ii) through

(iv) of this section. * * *

* * * * *

(k) * * *

(2) Prior periods. With respect to the

portion of a consolidated group’s first

taxable year ending after December 21,

2017, and for taxable years beginning

after December 21, 2017, and on or

before March 13, 2020, a consolidated

group may choose either—

* * * * *

■Par. 11. Section 1.1504–3 is amended:

■a. In the paragraph (b) subject

heading, by removing ‘‘affiliation’’ and

adding in its place ‘‘consolidation’’;

■b. In the first sentence of paragraph

(b)(1), by removing ‘‘the issuer’’ and

adding in its place ‘‘any corporation’’;

■c. In the last sentence of paragraph

(d)(1)(ii), by removing ‘‘–1.1502–100’’

and adding in its place ‘‘1.1502–100’’;

and

■d. By revising paragraph (e)(2)

introductory text.

The revision reads as follows:

§ 1.1504–3 Treatment of stock in a QOF C

corporation for purposes of consolidation.

* * * * *

(e) * * *

(2) Prior periods. With respect to the

portion of a consolidated group’s first

taxable year ending after December 21,

2017, and for taxable years beginning

after December 21, 2017, and on or

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19087

Federal Register / Vol. 85, No. 66 / Monday, April 6, 2020 / Rules and Regulations

before March 13, 2020, a consolidated

group may choose either—

* * * * *

Martin V. Franks,

Chief, Publications and Regulations Branch,

Legal Processing Division, Associate Chief

Counsel (Procedure and Administration).

[FR Doc. 2020–07013 Filed 4–1–20; 4:15 pm]

BILLING CODE 4830–01–P

DEPARTMENT OF HOMELAND

SECURITY

Coast Guard

33 CFR Part 165

[Docket No. USCG–2020–0036]

Safety Zones; Annual Events in the

Captain of the Port Buffalo Zone

AGENCY

: Coast Guard, DHS.

ACTION

: Notice of enforcement of

regulation.

SUMMARY

: The Coast Guard will enforce

a safety zone located in federal

regulations for a recurring marine event.

This action is necessary and intended

for the safety of life and property on

navigable waters during this event.

During the enforcement period, no

person or vessel may enter the

respective safety zone without the

permission of the Captain of the Port

Buffalo.

DATES

: The regulations in 33 CFR

165.939 listed in entry (b)(12) in Table

165.939 will be enforced from 6:45 a.m.

through 10:45 a.m. on July 18, 2020.

FOR FURTHER INFORMATION CONTACT

: If

you have questions about this notice of

enforcement, call or email LT William

Fitzgerald, Chief of Waterways

Management, U.S. Coast Guard Marine

Safety Unit Cleveland; telephone 216–

937–0124, email william.j.fitzgerald@

uscg.mil.

SUPPLEMENTARY INFORMATION

: The Coast

Guard will enforce the section entitled

Safety Zones; Annual Events in the

Captain of the Port Buffalo Zone listed

in in table 165.939 entry (b)(12) in 33

CFR 165.939 for the Lake Erie Open

Water Swim. Pursuant to 33 CFR

165.23, entry into, transiting, or

anchoring within the safety zone during

an enforcement period is prohibited

unless authorized by the Captain of the

Port Buffalo or her designated

representative. Those seeking

permission to enter the safety zone may

request permission from the Captain of

Port Buffalo via channel 16, VHF–FM.

Vessels and persons granted permission

to enter the safety zone shall obey the

directions of the Captain of the Port

Buffalo or her designated representative.

While within a safety zone, all vessels

shall operate at the minimum speed

necessary to maintain a safe course.

This notice of enforcement is issued

under authority of 33 CFR 165.939 and

5 U.S.C. 552 (a). In addition to this

notice of enforcement in the Federal

the maritime community with advance

notification of this enforcement period

via Broadcast Notice to Mariners or

Local Notice to Mariners. If the Captain

of the Port Buffalo determines that the

safety zone need not be enforced for the

full duration stated in this notice she

may use a Broadcast Notice to Mariners

to grant general permission to enter the

respective safety zone.

Lexia M. Littlejohn,

Captain, U.S. Coast Guard, Captain of the

Port Buffalo.

[FR Doc. 2020–07048 Filed 4–3–20; 8:45 am]

BILLING CODE 9110–04–P

ENVIRONMENTAL PROTECTION

AGENCY

40 CFR Part 52

[EPA–R01–OAR–2020–0150; FRL–10007–

40–Region 1]

Air Plan Approval; New Hampshire;

Negative Declaration for the Oil and

Gas Industry

AGENCY

: Environmental Protection

Agency (EPA).

ACTION

: Direct final rule.

SUMMARY

: The Environmental Protection

Agency (EPA) is approving a State

Implementation Plan (SIP) revision

submitted by the State of New

Hampshire. The revision provides the

state’s determination, via a negative

declaration, that there are no facilities

within its borders subject to EPA’s 2016

Control Technique Guideline (CTG) for

the oil and gas industry. The intended

effect of this action is to approve this

item into the New Hampshire SIP. This

action is being taken in accordance with

the Clean Air Act (CAA).

DATES

: This direct final rule will be

effective June 5, 2020, unless EPA

receives adverse comments by May 6,

2020. If adverse comments are received,

EPA will publish a timely withdrawal of

the direct final rule in the Federal

rule will not take effect.

ADDRESSES

: Submit your comments,

identified by Docket ID No. EPA–R01–

OAR–2020–0150 at https://

www.regulations.gov, or via email to

mcconnell.robert@epa.gov. For

comments submitted at Regulations.gov,

follow the online instructions for

submitting comments. Once submitted,

comments cannot be edited or removed

from Regulations.gov. For either manner

of submission, the EPA may publish any

comment received to its public docket.

Do not submit electronically any

information you consider to be

Confidential Business Information (CBI)

or other information whose disclosure is

restricted by statute. Multimedia

submissions (audio, video, etc.) must be

accompanied by a written comment.

The written comment is considered the

official comment and should include

discussion of all points you wish to

make. The EPA will generally not

consider comments or comment

contents located outside of the primary

submission (i.e. on the web, cloud, or

other file sharing system). For

additional submission methods, please

contact the person identified in the

FOR

FURTHER INFORMATION CONTACT

section.

For the full EPA public comment policy,

information about CBI or multimedia

submissions, and general guidance on

making effective comments, please visit

https://www.epa.gov/dockets/

commenting-epa-dockets. Publicly

available docket materials are available

at https://www.regulations.gov or at the

U.S. Environmental Protection Agency,

EPA Region 1 Regional Office, Air and

Radiation Division, 5 Post Office

Square—Suite 100, Boston, MA. EPA

requests that if at all possible, you

contact the contact listed in the

FOR

FURTHER INFORMATION CONTACT

section to

schedule your inspection. The Regional

Office’s official hours of business are

Monday through Friday, 8:30 a.m. to

4:30 p.m., excluding legal holidays.

FOR FURTHER INFORMATION CONTACT

: Bob

McConnell, Environmental Engineer,

Air and Radiation Division (Mail Code

05–2), U.S. Environmental Protection

Agency, Region 1, 5 Post Office Square,

Suite 100, Boston, Massachusetts,

02109–3912; (617) 918–1046.

mcconnell.robert@epa.gov.

SUPPLEMENTARY INFORMATION

Throughout this document whenever

‘‘we,’’ ‘‘us,’’ or ‘‘our’’ is used, we mean

EPA.

Table of Contents

I. Background

II. Summary of SIP Revision and EPA

Analysis

III. Final Action

IV. Statutory and Executive Order Reviews

I. Background

On October 27, 2016, EPA published

in the Federal Register the ‘‘Final

Control Techniques Guidelines for the

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Investing in Qualified Opportunity Funds; Correcting Amendments

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