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On April 17, 2019, the Internal Revenue Service (the "Service") issued a second round of Proposed Regulations (REG-120186-18) (the "April Regulations") providing an additional 169 pages of guidance on the Opportunity Zone program. The Tax Cuts and Jobs Act, P.L. 115-97, added new Section 1400Z-2 of the Internal Revenue Code (the "Code") which created Qualified Opportunity Funds ("QOF").
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