Enacted in 2017 by Congress's Tax Cuts and Jobs Act, the opportunity zone program is designed to create jobs and drive investment into certain low-income communities located in economically distressed census tracts designated by the state.

The program allows investors the opportunity to invest eligible gains into Qualified Opportunity Zone Funds, which will then make investments into low-income communities and allow investors to defer gains.

This presentation will discuss the various components of an opportunity zone transaction, including what qualifies as a Qualified Opportunity Zone Fund, a Qualified Opportunity Zone Business Property, and a Qualified Opportunity Zone Business.

The webinar will also cover types of eligible gains and how such transactions are structured.What You'll Learn:Purpose of the Opportunity Zone Provisions as Noted in the Anti-Abuse Provisions

Benefits of Investing in an Opportunity Zone

• For the Investor
  
• For the Business

Eligible Gain

• Gain From Sales of Capital Assets (1221(a))
  
• Gross Section 1231 Gains
  
• Other Types of Capital Gain
  
• Installment Sales
  
• Application of Related Party Rules and Step Transaction
  
• Rollover Gains

Qualified Opportunity Fund (QOF)

• Partnership or Corporation: Advantages and Disadvantages
  
• Carried Interests
  
• Partnerships Among Related Persons
  
• Compliance Testing; Measuring the Value of Assets

Qualified Opportunity Zone Business Property (QOZBP)

• Basic Definition
  
• Original Use
  
• Vacant Property
  
• Leased Property
  
• Substantial Improvement
  
• Aggregation

Qualified Opportunity Zone Business (QOZB)

• Basic Definition
  
• Source of Income: Employee Services, Income Generated, Management Functions
  
• Advantages of Invest in a QOZB Over Assets
  
• Net-Leasing
  
• Working Capital Plans
  
• Intangible Property
  
• Subsidiaries

Anti-Abuse Rules

Interaction With Other Tax Subsidies

• HTC
  
• Energy Property

Sales of an Interest in a QOZB or of Assets by QOZB

• After 10 Years
  
• Before 10 Years
  
• Exit of a Non-QOF Partner
  
• Recapitalization