InfO-Zone blog

Dan Ryan

Dan's practice focuses on representing taxpayers in federal and state tax litigation and controversies as well as transactional planning involving corporate, franchise, personal income and sales/use tax matters. Prior to his employment at Sullivan, Dan was an attorney at the Internal Revenue Service Office of Chief Counsel, where he represented the Internal Revenue Service in litigation before the United States Tax Court and served as a Special Assistant United States Attorney for the District of Massachusetts.

Recent Posts

Massachusetts Department of Revenue Issues Draft Technical Information Release Addressing Opportunity Zones

Posted by Dan Ryan on May 10, 2019 5:17:08 PM

On May 9, 2019, the Massachusetts Department of Revenue issued for practitioner comment a working draft Technical Information Release ("TIR") addressing the Massachusetts corporate excise and personal income tax ramifications of the federal Opportunity Zone provisions. Due to the different dates upon which Massachusetts conforms to the Internal Revenue Code (the "Code"), corporations will benefit and individuals will not.

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Topics: Opportunity Zones

Structuring Opportunity Zone Funds

Posted by Dan Ryan on Oct 26, 2018 4:38:32 PM

The Opportunity Zones Program created by the U.S. Tax Cut and Jobs Act of 2017 (the "OZone Program") and the first wave of proposed regulations issued by the Treasury Department on October 19, 2018 (the "Regulations") have been designed to generate economic activity in low-income urban and rural communities. Sullivan & Worcester’s Opportunity Zones Practice Group has analyzed the OZone Program and Regulations and has successfully structured multiple Qualified Opportunity Funds ("QOFs") with an anticipated aggregate capital raise of nearly $600 million.

As we and our clients continue to develop innovative QOF structures, we will provide a series of advisories that highlight specific structuring elements that are consistent with the OZone Program and the Regulations.

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Topics: capital gains, Opportunity Zones, Qualified Opportunity Funds, QOF

Sullivan

About the Blog


Sullivan's InfO-Zone blog features insight and analysis about Opportunity Zones, written by our multi-disciplinary team of lawyers from our Tax, Real Estate, Affordable Housing and Corporate practice groups. 

The material on this site is for general information only and is not legal advice. No liability is accepted for any loss or damage which may result from reliance on it. Always consult a qualified lawyer about a specific legal problem.

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