Publications & Presentations
October 24, 2018

This webinar was previously recorded on October 24, 2018. To view the webinar click here.  

Opportunity Zones Webinar: IRS Proposed Regulations for OZ Funds

October 24, 2018 | 8:30 a.m. - 9:00 a.m.

Treasury issued long-awaited Proposed Regulations and a Revenue Ruling October 19, 2018, regarding key issues involved with investing in and forming Qualified Opportunity Zone Funds (“OZ Fund”) and the OZ Fund’s investments in Opportunity Zone Businesses (“OZ Business”). Although the Proposed Regulations do not answer all of our key questions, Treasury did provide generally taxpayer friendly guidance to the issues discussed below.


• Treatment of Land, Capital Gains of Partnerships and other Pass-Thru Entities, and Working Capital

• Only 70% of an OZ Business’ Tangible Assets Need to be OZ Property

• The OZ Fund Can Borrow Money

• “Gains” are Limited to Gains Treated as Capital Gain

• Special Allocations are Permitted

• Early Disposition of OZ Fund interest

• Valuation of Assets for Purposes of the 90% Test

• 90% Asset Test Testing Dates

• Limited Liability Companies (LLCs) Can Be OZ Funds


Korb Maxwell, Shareholder, Real Estate | Opportunity Zones

S. Patrick O'Bryan, Shareholder, Tax | Opportunity Zones

Jeffrey A. Goldman, Shareholder, Tax | Opportunity Zones