Tax
Aug. 2, 2019
IRC Section 1231 enters the opportunity twilight zone
In recent weeks, one of the most hotly debated topics has been the treatment of Internal Revenue Code Section 1231 gains invested in an opportunity zone — which offers tax incentives to investors who deploy capital through a qualified opportunity fund.





Phil Jelsma
Partner and Chair of the Tax Practice Team
Crosbie Gliner Schiffman Southard & Swanson LLC (CGS3)
Email: pjelsma@cgs3.com
Phil is chair of the tax practice team at CGS3. He is recognized as a leading joint venture and tax attorney, with a 30-year background in real estate exchange transactions, syndications, nonprofit corporations and international tax planning.
In recent weeks, one of the most hotly debated topics has been the treatment of Internal Revenue Code Section 1231 gains invested in an opportunity zone — which offers tax incentives to investors who deploy capital through a qualified opportunity fund.
Generally, Section 1231 gain is net gain attributable to the sale or exchange of depreciable property used in a trade or business. As an example, a factory or warehouse used in a man...
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