Description
Understand various components of opportunity zone transactions and how such transactions are structured.Enacted in 2017 by Congress’s Tax Cuts and Jobs Act, the opportunity zone program is designed to create jobs and drive investment into certain lowincome communities located in economically distressed census tracts designated by the state. The program allows investors the opportunity to invest eligible gains into Qualified Opportunity Zone Funds, which will then make investments into lowincome communities and allow investors to defer gains.This presentation will discuss the various components of an opportunity zone transaction, including what qualifies as a Qualified Opportunity Zone Fund, a Qualified Opportunity Zone Business Property, and a Qualified Opportunity Zone Business. The topic will also cover types of eligible gains and how such transactions are structured.
Date: 2023-03-29 Start Time: End Time:
Learning Objectives
Purpose of the Opportunity Zone Provisions as Noted in the Anti-Abuse Provisions
Benefits of Investing in an Opportunity Zone
• For the Investor
• For the Business
Eligible Gain
• Gain From Sales of Capital Assets (1221(a))
• Gross Section 1231 Gains
• Other Types of Capital Gain
• Installment Sales
• Application of Related Party Rules and Step Transaction
• Rollover Gains
Qualified Opportunity Fund (QOF)
• Partnership or Corporation: Advantages and Disadvantages
• Carried Interests
• Partnerships Among Related Persons
• Compliance Testing; Measuring the Value of Assets
Qualified Opportunity Zone Business Property (QOZBP)
• Basic Definition
• Original Use
• Vacant Property
• Leased Property
• Substantial Improvement
• Aggregation
Qualified Opportunity Zone Business (QOZB)
• Basic Definition
• Active Business
• Source of Income: Employee Services, Income Generated, Management Functions
• Advantages of Invest in a QOZB Over Assets
• Net-Leasing
• Working Capital Plans
• Intangible Property
• Subsidiaries
Anti-Abuse Rules
Interaction With Other Tax Subsidies
• HTC
• Energy Property
Sales of an Interest in a QOZB or of Assets by QOZB
• After 10 Years
• Before 10 Years
• Exit of a Non-QOF Partner
• Recapitalization
CLE (Please check the Detailed Credit Information page for states that have already been approved) ,Additional credit may be available upon request. Contact Lorman at 866-352-9540 for further information.
A. Ann Hered-Butler Snow LLP, Thane R. Hodson – Butler Snow LLP
