On October 19, 2018, the Internal Revenue Service issued proposed regulations for the deferral of gain under Code Sec. 1400Z-2 Qualified Opportunity Zone (QOZ) tax incentives. The purpose of the proposed regulations is to provide expanded clarity for the eligibility for deferral treatment. While the regulations are proposed, taxpayers and tax practitioners may rely on the guidance until final regulations are issued. The following memo is intended to broadly highlight key provisions of the proposed regulations.