Qualified Opportunity Zones

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
 
Publications
 
DATE TITLE
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
 
 
Events         [Return to top]
 
DATE TITLE
March 6, 2019: Opportunity Zones in 2019 webinar Opportunity Zones in 2019: Maximizing Benefits for Your Firm
February 26, 2019: Stroock and KPMG's The Latest Insights on QOZs and Impact Investing
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
 
 
Related Materials          [Return to top]
 
DESCRIPTION LINK
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
 

Back To Service

Lawyers In This Group


NAME TITLE OFFICE
Elsa A. Ben Shimon Partner New York

Elsa A. Ben Shimon
Partner
New York

Micah W. Bloomfield Senior Counsel New York

Micah W. Bloomfield
Senior Counsel
New York

Brian Diamond Partner New York

Brian Diamond
Partner
New York

Michael S. Emanuel Partner New York

Michael S. Emanuel
Partner
New York

Mayer Greenberg Partner New York

Mayer Greenberg
Partner
New York

Evan Hudson Partner New York

Evan Hudson
Partner
New York

Michelle M. Jewett Partner New York

Michelle M. Jewett
Partner
New York

Richard G. Madris Partner New York

Richard G. Madris
Partner
New York

Kevin Matz Partner New York

Kevin Matz
Partner
New York

Ross F. Moskowitz Partner New York

Ross F. Moskowitz
Partner
New York

André B. Nance Partner New York

André B. Nance
Partner
New York

Eric Requenez Partner New York

Eric Requenez
Partner
New York

Brian J. Senie Associate New York

Brian J. Senie
Associate
New York

Jeffrey D. Uffner Partner New York

Jeffrey D. Uffner
Partner
New York