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.
Who Should Participate in Qualified Opportunity Zones?
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
NewsBack To Service
April 10, 2019 | American College of Trust and Estate Counsel
Kevin Matz Talks Qualified Opportunity Funds, Opportunity Zones on ACTEC Podcast
March 11, 2019 | Commercial Observer
Evan Hudson, Mayer Greenberg and Brian Senie Published in Commercial Observer
February 13, 2019 | Press Release
Stroock Formalizes Israeli Practice with Addition of Partner Elsa Ben Shimon
February 4, 2019 | Real Estate Weekly
Evan Hudson Published in Real Estate Weekly
January, 31 2019 | Compliance Week
Kevin Matz, Mayer Greenberg Talk QOZs With Compliance Week
December 13, 2018 | Commercial Observer
Loryn Arkow Featured in “LA’s Top Landlords Talk Value Creation and Opportunity Zones”
PublicationsBack To Service
April 19, 2019 | Stroock Special Bulletin
They’re Out! Stroock’s Take on the Second Set of Proposed QOZ Regulations
November 6, 2018 | Stroock Special Bulletin
Six Burning Questions on the New Qualified Opportunity Zone Guidance
October 19, 2018 | Stroock Special Bulletin
Stroock’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’”By: Kevin Matz
EventsBack To Service
May 23, 2019
NYSSCPA's Annual Estate Planning Conference
March 20, 2019
Opportunity Zones in 2019: Maximizing Benefits for Your Firm
March 20-24, 2019
The American College of Trust and Estate Counsel’s 2019 Annual Meeting
February 25, 2019
New York Tax Study Group Meeting
January 23, 2019
NYSSCPA’s Partnerships and LLCs Taxation Conference
November 15, 2018
Qualified Opportunity Zones: Pros and Pitfalls
November 8, 2018
Family Office Symposium
Lawyers In This GroupBack To Service
|Elsa A. Ben Shimon||Partner||
|Brian J. Senie||Associate||
|André B. Nance||Partner||
|Richard G. Madris||Partner||
|Michelle M. Jewett||Partner||
|Micah W. Bloomfield||Senior Counsel||
|Ross F. Moskowitz||Partner||
|Michael S. Emanuel||Partner||
|Jeffrey D. Uffner||Partner||