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May 14, 2018

Opportunity Zones: A Preliminary Examination

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The Tax Cuts and Jobs Act of 2017 (the “Act”) made significant changes to U.S. federal tax law. One of these changes was the establishment of a new tax regime relating to qualified opportunity zones (“Opportunity Zones”) under Sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the “Code”), to encourage private investment in distressed communities throughout the United States. Investors that wish to defer capital gains recognized upon a sale or exchange of an asset to an unrelated  party on or prior to December 31, 2026 can invest that gain in a Qualified Opportunity Fund (QOF), which in turn invests in so-called “qualified opportunity zone property.” This newsletter will discuss the current status of the Opportunity Zone program, the tax benefits associated with investing in QOFs, what qualifies as qualified opportunity zone property and issues relevant to sponsors in connection with the formation of QOFs.

Read full memo, Opportunity Zones: A Preliminary Examination

Authors and Contributors

Lisa M. Brill

Partner

Real Estate

+1 212 848 4571

+1 212 848 4571

New York

Laura Friedrich

Partner

Investment Funds

+1 212 848 7411

+1 212 848 7411

New York

Michael Shulman

Partner

Tax

+1 212 848 8080

+1 212 848 8080

New York

Derek Kershaw

Counsel

Tax

+1 212 848 7964

+1 212 848 7964

New York