Our multidisciplinary team is composed of recognized thought leaders in the evolving realm of the recently enacted Qualified Opportunity Zone (QOZ) program. We are actively engaged in transactional work with QOZ assets and are navigating the regulatory changes in real time as the QOZ landscape continues to come into focus.We help our clients unlock the benefits of the QOZ program by developing strategies to raise QOZ advantaged “rollover” capital, creating tax compliant Qualified Opportunity Funds, and maximizing the value of QOZ assets. We are actively involved with a broad spectrum of QOZ assets, including all categories of real estate, as well as energy, infrastructure and other active business projects. By creating a team that combines our understanding of the QOZ program and its requirements with our business-minded approach and experience in real estate, infrastructure, energy, private equity, fund formation and design and securities compliance, we are able to provide thoughtful and comprehensive advice to help our clients achieve their goals.
What Is a Qualified Opportunity Zone and Qualified Opportunity Fund?
The 2017 Tax Cuts and Jobs Act created a new program for QOZs that offers potentially significant tax incentives for investors to help attract funding for projects and businesses in economically distressed communities nationwide.
An Opportunity Zone is an economically distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment. A Qualified Opportunity Fund (QOF) is a fund that generally invests its assets in businesses or tangible property located in Opportunity Zones.
What Are the Tax Benefits?
Investors can achieve three significant tax benefits:
- The ability to defer taxable gain realized on the sale or disposition of property until as late as December 31, 2026, if the gains are invested in a QOF within 180 days of the property’s disposition.
- The elimination of up to 15% of the gain that has been reinvested in a QOF provided that certain holding period requirements are met.
- The potential elimination of tax on gains associated with the appreciation in the value of a QOF, provided that the investment in the QOF is held for at least 10 years.
Real estate developers, investment managers, fund sponsors, family offices, foreign investors with U.S. capital gains, institutional and private investors, entrepreneurs, small to large businesses, infrastructure funds, solar developers, cities, and urban and rural economic development associations.
Stroock provides readers a deep-dive into various elements of the act, including changes to the estate and gift taxes, the treatment of compensation and carried interests, significantly reduced rates for corporate taxpayers and for many individual members of partnerships and LLCs, the elimination of all but $10,000 of the deduction for state and local income taxes and non-business real property taxes, the repeal of the corporate AMT, the end of accumulated built-up tax deferral for multinational corporations with foreign subsidiaries and new minimum taxes which tax significant portions of future deferrals, new limitations on the deductibility of interest by corporations and partnerships, and changes to the treatment of executive compensation.
For more information on Qualified Opportunity Zones, please see below.
Jump to: Publications | Events | Related Materials
|November 27, 2018||Qualified Opportunity Zones: More of Your Questions Answered|
|November 6, 2018||Six Burning Questions on the New Qualified Opportunity Zone Guidance|
|October 19, 2018||Stroock's Take on the New 'Qualified Opportunity Zone' Guidance|
|August 28, 2018||Qualified Opportunity Funds: Tax Strategies and Opportunities for Real Estate and Other Investors|
|July 17, 2018||When Opportunity Knocks to Defer Tax on Gains - 'Qualified Opportunity Funds"
Also published in TaxStringer
|January 22, 2019: Opportunity Zones in 2019 webinar||Opportunity Zones in 2019: Maximizing Benefits for Your Firm|
|November 29, 2018: Stroock-sponsored||The Riverside Experience's Opportunity Zone Conference & Real Estate Gala Networking Reception|
|November 15, 2018: Stroock’s||Qualified Opportunity Zones: Pros and Pitfalls|
|November 8, 2018: Stroock’s||Family Office Symposium|
|Webinar recording||Qualified Opportunity Funds Webinar|
|Qualified Opportunity Zone Overview||Qualified Opportunity Zone Overview|
|Qualified Opportunity Zones presentation||Qualified Opportunity Zones and Qualified Opportunity Funds|
In The Spotlight
January 2019|Compliance WeekKevin Matz, Mayer Greenberg Talk QOZs With Compliance Week
December 13, 2018|Commercial ObserverLoryn Arkow Featured in “LA’s Top Landlords Talk Value Creation and Opportunity Zones”
November 27, 2018|Stroock CommentaryQualified Opportunity Zones: More of Your Questions Answered
November 6, 2018|Stroock Special BulletinSix Burning Questions on the New Qualified Opportunity Zone Guidance
October 19, 2018|Stroock Special BulletinStroock’s Take on the New ‘Qualified Opportunity Zone’ Guidance
August 28, 2018|Stroock Special Bulletin“Qualified Opportunity Funds: Tax Strategies and Opportunities for Real Estate and Other Investors”
August 1, 2018|TaxStringer“When Opportunity Knocks to Defer Tax on Gains: ‘Qualified Opportunity Funds’”
March 20-24, 2019The American College of Trust and Estate Counsel’s 2019 Annual Meeting
February 25, 2019New York Tax Study Group Meeting
January 23, 2019NYSSCPA’s Partnerships and LLCs Taxation Conference
UpcomingOpportunity Zones in 2019: Maximizing Benefits for Your Firm
November 15, 2018Qualified Opportunity Zones: Pros and Pitfalls
November 8, 2018Family Office Symposium
Lawyers In This Group
|Micah W. Bloomfield||Senior Counsel||New York||
Micah W. Bloomfield
|Brian Diamond||Partner||New York||
|Michael S. Emanuel||Partner||New York||
Michael S. Emanuel
|Mayer Greenberg||Partner||New York||
|Evan Hudson||Partner||New York||
|Michelle M. Jewett||Partner||New York||
Michelle M. Jewett
|Richard G. Madris||Partner||New York||
Richard G. Madris
|Kevin Matz||Partner||New York||
|Ross F. Moskowitz||Partner||New York||
Ross F. Moskowitz
|André B. Nance||Partner||New York||
André B. Nance
|Eric Requenez||Partner||New York||
|Brian J. Senie||Associate||New York||
Brian J. Senie
|Jeffrey D. Uffner||Partner||New York||
Jeffrey D. Uffner