Qualified Opportunity Zones and Opportunity Fund Formation
Greenberg Traurig’s Opportunity Zone Team advises investors, funds, sponsors, developers, and operating businesses seeking to maximize the value of Qualified Opportunity Zone benefits – tax incentives created by the 2017 Tax Cuts and Jobs Act to encourage long-term investment in targeted urban and rural communities across the country. Comprising tax and real estate attorneys, GT’s Opportunity Zone Team helps investors, fund managers, and businesses identify and structure the benefits of the new Qualified Opportunity Zone incentive.
These tax incentives enable real estate investors, private equity, operating business investors, and venture capital firms to abate current capital gain tax liability and receive tax-free treatment on all future appreciation. The legislation adopts a new tax incentive for deferring up to 100% of capital gains tax upon a sale or disposition of property or a business when such gains are invested into qualified long-term investments in these targeted Qualified Opportunity Zone communities. The GT team is experienced in complex transactions that utilize federal and state tax incentives, including Qualified Opportunity Funds, and developing creative structures designed to help increase benefits and ameliorate risks.
Our areas of representation include:
- Formation of Qualified Opportunity Funds (QOFs)
- QOF qualification requirements
- Formation of Qualified Opportunity Zone Businesses (QOZBs)
- Compliance with related party purchase and lease rules
- Documentation flexibility in light of new proposed Treasury Regulations