On October 19, 2018, the IRS released eagerly-awaited regulations, a revenue ruling and a tax form that provide guidance needed to implement the Opportunity Zone Fund program, which was enacted as part of the 2017 tax reform legislation. The Opportunity Zone Fund program offers substantial tax benefits to taxpayers that reinvest capital gains from the sale of existing investments into a Qualified Opportunity Fund ("QOF"). A QOF must invest in property or businesses in certain low-income communities, identified as Qualified Opportunity Zones. Timely investment in a QOF makes taxpayers eligible for deferral of tax on and a partial basis step up with respect to the rolled-over old gain and an exclusion of 100 percent of gain attributable to the taxpayer's new investment in the QOF. Our earlier guidance, which will be updated in detail, is available here.