{"abstract":"This document contains proposed regulations that include requirements that certain foreign persons and certain foreign-owned partnerships must meet in order to elect the Federal income tax benefits provided by section 1400Z-2 of the Internal Revenue Code (Code). This document also contains proposed regulations that allow, under certain circumstances, for the reduction or elimination of withholding under section 1445, 1446(a), or 1446(f) of the Code on transfers that give rise to gain that is deferred under section 1400Z- 2(a). Finally, this document contains additional guidance regarding the 24-month extension of the working capital safe harbor in the case of Federally declared disasters. The proposed regulations affect qualified opportunity funds and their investors.","action":"Notice of proposed rulemaking.","agencies":[{"raw_name":"DEPARTMENT OF THE TREASURY","name":"Treasury Department","id":497,"url":"https://www.federalregister.gov/agencies/treasury-department","json_url":"https://www.federalregister.gov/api/v1/agencies/497","parent_id":null,"slug":"treasury-department"},{"raw_name":"Internal Revenue Service","name":"Internal Revenue Service","id":254,"url":"https://www.federalregister.gov/agencies/internal-revenue-service","json_url":"https://www.federalregister.gov/api/v1/agencies/254","parent_id":497,"slug":"internal-revenue-service"}],"body_html_url":"https://www.federalregister.gov/documents/full_text/html/2021/04/14/2021-06143.html","cfr_references":[{"chapter":null,"citation_url":null,"part":1,"title":26}],"citation":"86 FR 19585","comment_url":null,"comments_close_on":null,"correction_of":null,"corrections":[],"dates":"Written or electronic comments and requests for a public hearing must be received by June 11, 2021. Requests for a public hearing must be submitted as prescribed in the \"Comments and Requests for Public Hearing\" section.","disposition_notes":null,"docket_ids":["REG-121095-19"],"dockets":[],"document_number":"2021-06143","effective_on":null,"end_page":19599,"executive_order_notes":null,"executive_order_number":null,"explanation":null,"full_text_xml_url":"https://www.federalregister.gov/documents/full_text/xml/2021/04/14/2021-06143.xml","html_url":"https://www.federalregister.gov/documents/2021/04/14/2021-06143/requirements-for-certain-foreign-persons-and-certain-foreign-owned-partnerships-investing-in","images":{},"images_metadata":{},"json_url":"https://www.federalregister.gov/api/v1/documents/2021-06143?publication_date=2021-04-14","mods_url":"https://www.govinfo.gov/metadata/granule/FR-2021-04-14/2021-06143/mods.xml","not_received_for_publication":null,"page_length":15,"page_views":{"count":1232,"last_updated":"2026-04-24 20:15:02 -0400"},"pdf_url":"https://www.govinfo.gov/content/pkg/FR-2021-04-14/pdf/2021-06143.pdf","presidential_document_number":null,"proclamation_number":null,"public_inspection_pdf_url":"https://public-inspection.federalregister.gov/2021-06143.pdf?1618258819","publication_date":"2021-04-14","raw_text_url":"https://www.federalregister.gov/documents/full_text/text/2021/04/14/2021-06143.txt","regulation_id_number_info":{"1545-BP50":{"issue":"202304","html_url":"https://www.federalregister.gov/regulations/1545-BP50/foreign-investors-in-qualified-opportunity-zones","title":"Foreign Investors in Qualified Opportunity Zones","xml_url":"http://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202304&RIN=1545-BP50&operation=OPERATION_EXPORT_XML","priority_category":"Substantive, Nonsignificant"}},"regulation_id_numbers":["1545-BP50"],"regulations_dot_gov_info":{"supporting_documents":[],"regulatory_plan":{"html_url":"https://www.federalregister.gov/regulations/1545-BP50/foreign-investors-in-qualified-opportunity-zones","title":"Foreign Investors in Qualified Opportunity Zones"},"comments_count":4,"agency_id":"IRS","comments_url":"https://www.regulations.gov/docketBrowser?rpp=50&so=DESC&sb=postedDate&po=0&dct=PS&D=IRS-2021-0005","supporting_documents_count":0,"docket_id":"IRS-2021-0005","document_id":"IRS-2021-0005-0001","regulation_id_number":"1545-BP50","title":"Requirements for Certain Foreign Persons and Certain Foreign-Owned Partnerships Investing in Qualified Opportunity Funds and Flexibility for Working Capital Safe Harbor Plans (REG-121095-19)","checked_regulationsdotgov_at":"2022-02-08T04:30:05Z"},"regulations_dot_gov_url":null,"significant":false,"signing_date":null,"start_page":19585,"subtype":null,"title":"Requirements for Certain Foreign Persons and Certain Foreign-Owned Partnerships Investing in Qualified Opportunity Funds and Flexibility for Working Capital Safe Harbor Plans","toc_doc":"Requirements for Certain Foreign Persons and Certain Foreign-Owned Partnerships Investing in Qualified Opportunity Funds and Flexibility for Working Capital Safe Harbor Plans","toc_subject":null,"topics":["Income taxes","Reporting and recordkeeping requirements"],"type":"Proposed Rule","volume":86}