HomeWebcastOpportunity Zones Investment: Navigating Potentials
Online CPE Opportunity Zones CLE

Opportunity Zones Investment: Navigating Potentials

Live Webcast Date: Wednesday, July 17, 2019 from 3:00 pm to 5:00 pm (ET)
Taxation (CPE)Recording

Online CPE Opportunity Zones

Join us for this Knowledge Group Online CPE Opportunity Zones Webinar. Intended to spur job creation and economic development in distressed communities, the U.S. government has added Opportunity Zones to the tax code under the Tax Cuts and Jobs Act. The investment vehicle used is a Qualified Opportunity Fund (QOF) which can be a corporation or partnership. Investing in O-Zones benefits investors through tax incentives such as tax deferment.

However, amidst the potential tax savings, the program comes with possible risks. As O-Zone investments gain momentum in 2019, investors and counsel should be well-versed with the regulatory and economic updates to ensure that opportunities are maximized and pitfalls are avoided.

Our panel of key thought leaders and practitioners will offer a discussion of the fundamentals as well as the latest and significant issues surrounding the O-Zone investment and its investment tool – the QOF. This Webcast aims to help you optimize the benefits of O-Zone investments while avoiding common risk issues.

The panel will also discuss, among other topics:

  • Recent Updates and Developments
  • IRS Regulations on QOF and O-Zones
  • Challenges Encountered
  • Practical Strategies to Maximize Benefits

Agenda

Ryan C. FurtickAttorney
Lewis Rice LLC

  • Overview of Program
    • OZ Program Enacted as part of TCJA
    • Describe what an OZ is (i.e., designated low-income area)
    • Summary of 3 tax benefits from investing in OZ
      • Including timing and deferral for pass-through entities
    • Intro to defined terms (OZ Fund, OZ Property, OZ Stock, OZ Partnership Interest, OZ Business Property)
    • Eligible taxpayers, eligible gains, eligible interests
    • IRC Section 1231 netting and timing vs. direct capital gains vs. K-1 capital gains

Venroy K. JulyPrincipal
Miles & Stockbridge P.C.

  • QO Fund Qualification
    • More detailed analysis of relevant defined terms
    • Self-certification
    • 90% Test and the relaxing of this requirement under the new proposed regulations
    • Meaning of “substantially all” (70% vs. 90% depending on context)
    • Working capital safe harbor
    • Semi-Annual Testing dates

Michael T. DonovanMember
Lewis Rice LLC

  • Choice of Entity and QO Fund Structuring
    • partnership vs. S corporation vs. C corporation vs. REIT

Blake E. ChristianPartner
Holthouse Carlin & Van Trigt LLP

  • OZ Operating Business Issues
    • Substantially within OZ
    • Treatment of leased vs. purchased assets
    • Intangibles – 40% requirement
    • 50% gross income test (3 safe harbors and facts and circumstances test)
    • Purchasing existing OZ business vs. Relocating a business into an OZ

Venroy K. JulyPrincipal
Miles & Stockbridge P.C.

  • OZ Real Estate Issues
    • “original use”
    • “substantial improvement”
    • Issues with leasing property and when certain real estate activities constitute an active trade or business

Ryan C. FurtickAttorney
Lewis Rice LLC

  • Events Causing (or not) Inclusion of Deferred Gain
    • Debt-financed distributions
    • Income distributions
    • Transfer of interest/ Inclusion events
    • Impact on heir(s) upon death of QOF holder

Blake E. ChristianPartner
Holthouse Carlin & Van Trigt LLP

  • OZ Program with Other Tax Provisions  
    • Potential to accelerate 10 year period for gain exclusion under Section 1202
    • Potential interaction with NMTC or other tax incentives
    • Comparison with 1031 exchanges
  • State Tax Conformity Issues
    • Review of non-conforming states
    • States requiring “in-state” reinvestment/ Constitutional issues
    • What happens if state law does not conform to federal law?

Michael T. DonovanMember
Lewis Rice LLC

  • Exit Strategies
    • Pre-10-Year Period/ Post-10-year Period
    • Asset sales (only at QO Fund level, not in two-tier structure)
    • Equity sales
    • Sale of QOF interest to secondary investor

Who Should Attend

  • Business Managers
  • Business Analysts
  • Executive Board Members
  • Business Development Managers
  • Fund Managers
  • Investment Advisers
  • Investors
  • Developers
  • Financial Management Officers
  • Accountants
  • Tax Advisers
  • Tax Consultants
  • Other Related/Interested Professionals

Online CPE Opportunity Zones

Ryan C. FurtickAttorney
Lewis Rice LLC

  • Overview of Program
    • OZ Program Enacted as part of TCJA
    • Describe what an OZ is (i.e., designated low-income area)
    • Summary of 3 tax benefits from investing in OZ
      • Including timing and deferral for pass-through entities
    • Intro to defined terms (OZ Fund, OZ Property, OZ Stock, OZ Partnership Interest, OZ Business Property)
    • Eligible taxpayers, eligible gains, eligible interests
    • IRC Section 1231 netting and timing vs. direct capital gains vs. K-1 capital gains

Venroy K. JulyPrincipal
Miles & Stockbridge P.C.

  • QO Fund Qualification
    • More detailed analysis of relevant defined terms
    • Self-certification
    • 90% Test and the relaxing of this requirement under the new proposed regulations
    • Meaning of “substantially all” (70% vs. 90% depending on context)
    • Working capital safe harbor
    • Semi-Annual Testing dates

Michael T. DonovanMember
Lewis Rice LLC

  • Choice of Entity and QO Fund Structuring
    • partnership vs. S corporation vs. C corporation vs. REIT

Blake E. ChristianPartner
Holthouse Carlin & Van Trigt LLP

  • OZ Operating Business Issues
    • Substantially within OZ
    • Treatment of leased vs. purchased assets
    • Intangibles – 40% requirement
    • 50% gross income test (3 safe harbors and facts and circumstances test)
    • Purchasing existing OZ business vs. Relocating a business into an OZ

Venroy K. JulyPrincipal
Miles & Stockbridge P.C.

  • OZ Real Estate Issues
    • “original use”
    • “substantial improvement”
    • Issues with leasing property and when certain real estate activities constitute an active trade or business

Ryan C. FurtickAttorney
Lewis Rice LLC

  • Events Causing (or not) Inclusion of Deferred Gain
    • Debt-financed distributions
    • Income distributions
    • Transfer of interest/ Inclusion events
    • Impact on heir(s) upon death of QOF holder

Blake E. ChristianPartner
Holthouse Carlin & Van Trigt LLP

  • OZ Program with Other Tax Provisions  
    • Potential to accelerate 10 year period for gain exclusion under Section 1202
    • Potential interaction with NMTC or other tax incentives
    • Comparison with 1031 exchanges
  • State Tax Conformity Issues
    • Review of non-conforming states
    • States requiring “in-state” reinvestment/ Constitutional issues
    • What happens if state law does not conform to federal law?

Michael T. DonovanMember
Lewis Rice LLC

  • Exit Strategies
    • Pre-10-Year Period/ Post-10-year Period
    • Asset sales (only at QO Fund level, not in two-tier structure)
    • Equity sales
    • Sale of QOF interest to secondary investor

Online CPE Opportunity Zones

Online CPE Opportunity Zones

Ryan C. FurtickAttorneyLewis Rice LLC

Ryan C. Furtick practices in the Corporate Department of Lewis Rice. Ryan has experience with a wide variety of corporate matters, including structuring mergers and acquisitions, entity formation, and restructuring. Ryan also has experience in all aspects of tax planning for partnerships, LLCs, and corporations, including business and succession planning.

Prior to joining Lewis Rice, Ryan was an associate at Crady Jewett McCulley & Houren LLP in Houston, Texas.

Online CPE Opportunity Zones

Michael T. DonovanMemberLewis Rice LLC

Michael T. Donovan is Chairman of the Tax Department. Mike has significant experience in all aspects of tax planning for partnerships and LLCs, corporations, real estate, REITs, and funds. He regularly advises clients in connection with M&A transactions, real estate projects, and complex partnership issues. Mike also counsels exempt organizations on issues relating to tax-exempt status, intermediate sanctions, and joint ventures with for-profit entities. He has spoken and written extensively on a variety of tax topics, including a recent article for the Journal of Taxation on the complex FATCA final regulations.

Online CPE Opportunity Zones

Venroy K. JulyPrincipalMiles & Stockbridge P.C.

A principal at the law firm of Miles & Stockbridge, Venroy July differentiates his practice through his recognition of the interplay of business and legal considerations in the context of the contemporary economic climate, positioning himself to effectively work with clients to develop the appropriate strategies to accomplish their business goals.

Venroy’s diverse practice and experience have benefited clients operating in the government contracting, transportation, cybersecurity, banking and technology industries; he counsels on an array of matters that include the formation of private equity funds, including opportunity funds, equity and asset sales and purchases, debt offerings, and licensing transactions—among many other top-of-the-fold legal issues. While his practice focuses on larger transactions, he also regularly helps clients with myriad other business needs, including various forms of loan transactions, compliance with U.S. securities laws and general commercial matters.

Online CPE Opportunity Zones

Blake E. ChristianPartnerHolthouse Carlin & Van Trigt LLP

Blake Christian has over 38 years’ experience as a CPA, and has been a Tax Partner at HCVT, LLP (a Top 30 national CPA firm with 12 offices, over 600 members, and over 100 partners and principals) for 26 years. Prior to HCVT Blake was a Partner with KPMG in Los Angeles.

Blake provides tax and financial consulting and compliance services to clients that include multinational, publicly traded corporations, as well as closely held owner-managed businesses.  In addition to corporate, partnership and individual tax compliance and planning, Blake specializes in federal, state and local tax incentive, tax credits, grants and other benefits associated with hiring and investing. As a result of the 2017 Tax Cuts and Jobs Act Blake has also developed a specialty in the new federal Opportunity Zone Program. Blake assists in the federal and state tax analysis and planning for OZ reinvestments, fund formation, management, and compliance.

Blake has served on numerous community boards including, 2008 Chairman, Long Beach Area Chamber of Commerce and 2011 President, Rotary Club of Long Beach.  Blake received the 2016 Community Spirit Award from the Chamber, he was also named one of the Top 10 California Accountants (2014 & 2015), received the 2011 California Public Service Award from the California Society of CPAs. Treasurer of the Park City Egyptian Theater, and a member of the Utah Association of CPA’s tax Legislation Committee.


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Online CPE Opportunity Zones

Course Level:
   Intermediate

Advance Preparation:
   Print and review course materials

Method Of Presentation:
   On-demand Webcast; Group-Internet Based

Prerequisite:
   General knowledge of tax laws

Course Code:
   148148

NASBA Field of Study:
   Taxes - Technical

NY Category of CLE Credit:
   Areas of Professional Practice

Total Credits:
    2 NASBA-CPE

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About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

About the Knowledge Group

The Knowledge Group

The Knowledge Group has been a leading global provider of Continuing Education (CLE, CPE) for over 13 Years. We produce over 450 LIVE webcasts annually and have a catalog of over 4,000 on-demand courses.

Throughout the Firm's history, Lewis Rice attorneys have made excellence the foundation of their practice. Founded in 1909, more than a century of service gives the Firm the experience, resources and tools to serve our clients' dynamic needs. A diverse team of more than 160 attorneys provides counsel and solutions for the challenges facing local, regional and national businesses, as well as individuals and families. Lewis Rice maintains offices in downtown St. Louis, suburban Town & Country, Washington and Jefferson City, Missouri and Edwardsville, Illinois. The Firm also has offices in downtown Kansas City, Missouri and suburban Overland Park, Kansas.

Website: https://www.lewisrice.com/

Miles & Stockbridge is a leading AmLaw 200 law firm with offices throughout the mid-Atlantic region. Our more than 240 lawyers help global, national, local and emerging business clients preserve and create value by helping them solve their most challenging problems.

As a firm, our premier focus areas include corporate, government contracts, intellectual property, products liability and real estate law. To learn more about what we can do for you, a robust assemblage of our service areas can be found on our website at www.milesstockbridge.com

Website: http://www.milesstockbridge.com

Founded in 1991, HCVT is one of the fastest growing CPA firms in the nation, validating the technical experience of our team and our approach to client service. We provide tax, accounting, business management, and mergers & acquisitions services to private companies, closely-held businesses, public companies, high net worth individuals and family offices. We provide audit and assurance services to privately held businesses, funds, and employee benefit plans. Today, we are the fifth largest CPA firm in Los Angeles with a team of over 600 members, including over 100 partners and principals. We serve our clients from eight offices in Southern California and offices in Walnut Creek, California, Fort Worth, Texas, Park City, Utah, and Phoenix, Arizona. Our national and global reach is extended by our affiliation with Moore Stephens North America, an independent and global accountancy and business advisory association of affiliated CPA and financial services firms throughout the United States and the globe.

Website: https://www.hcvt.com/

Ryan C. Furtick practices in the Corporate Department of Lewis Rice. Ryan has experience with a wide variety of corporate matters, including structuring mergers and acquisitions, entity formation, and restructuring. Ryan also has experience in all aspects of tax planning for partnerships, LLCs, and corporations, including business and succession planning.

Prior to joining Lewis Rice, Ryan was an associate at Crady Jewett McCulley & Houren LLP in Houston, Texas.

Michael T. Donovan is Chairman of the Tax Department. Mike has significant experience in all aspects of tax planning for partnerships and LLCs, corporations, real estate, REITs, and funds. He regularly advises clients in connection with M&A transactions, real estate projects, and complex partnership issues. Mike also counsels exempt organizations on issues relating to tax-exempt status, intermediate sanctions, and joint ventures with for-profit entities. He has spoken and written extensively on a variety of tax topics, including a recent article for the Journal of Taxation on the complex FATCA final regulations.

A principal at the law firm of Miles & Stockbridge, Venroy July differentiates his practice through his recognition of the interplay of business and legal considerations in the context of the contemporary economic climate, positioning himself to effectively work with clients to develop the appropriate strategies to accomplish their business goals.

Venroy’s diverse practice and experience have benefited clients operating in the government contracting, transportation, cybersecurity, banking and technology industries; he counsels on an array of matters that include the formation of private equity funds, including opportunity funds, equity and asset sales and purchases, debt offerings, and licensing transactions—among many other top-of-the-fold legal issues. While his practice focuses on larger transactions, he also regularly helps clients with myriad other business needs, including various forms of loan transactions, compliance with U.S. securities laws and general commercial matters.

Blake Christian has over 38 years’ experience as a CPA, and has been a Tax Partner at HCVT, LLP (a Top 30 national CPA firm with 12 offices, over 600 members, and over 100 partners and principals) for 26 years. Prior to HCVT Blake was a Partner with KPMG in Los Angeles.

Blake provides tax and financial consulting and compliance services to clients that include multinational, publicly traded corporations, as well as closely held owner-managed businesses.  In addition to corporate, partnership and individual tax compliance and planning, Blake specializes in federal, state and local tax incentive, tax credits, grants and other benefits associated with hiring and investing. As a result of the 2017 Tax Cuts and Jobs Act Blake has also developed a specialty in the new federal Opportunity Zone Program. Blake assists in the federal and state tax analysis and planning for OZ reinvestments, fund formation, management, and compliance.

Blake has served on numerous community boards including, 2008 Chairman, Long Beach Area Chamber of Commerce and 2011 President, Rotary Club of Long Beach.  Blake received the 2016 Community Spirit Award from the Chamber, he was also named one of the Top 10 California Accountants (2014 & 2015), received the 2011 California Public Service Award from the California Society of CPAs. Treasurer of the Park City Egyptian Theater, and a member of the Utah Association of CPA’s tax Legislation Committee.

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