The IRS’s proposed 50-percent gross income locational rule on the active conduct of Opportunity Zone businesses is garnering criticism from stakeholders and lawmakers alike. The IRS released proposed regulations, NPRM REG-115420-18, for tax reform’s Opportunity Zone program last October, (TAXDAY, 2018/10/30, M.1). 50-Percent Locational Rule Many stakeholders have urged the IRS to reconsider its proposed […]
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