HomeWebcastOpportunity Zones & Opportunity Funds: Promises and Perils in 2019
Online CLE Opportunity Zone CLE

Opportunity Zones & Opportunity Funds: Promises and Perils in 2019

Live Webcast Date: Thursday, May 23, 2019 from 12:00 pm to 1:30 pm (ET)
CPE TaxationRecording

Online CLE Opportunity Zone

Join us for this Knowledge Group Online CLE Opportunity Zone Webinar. Qualified opportunity zones (QOZ) are emerging as a significant economic development tool to help economically distressed areas to prosper. Under the QOZ program, investors are encouraged to invest in qualified opportunity funds (QOF) through tax incentives. While investors are drawn to QOZ and QOF because of the tax benefits, the evolving regulatory paradigm of tax laws should also be underscored. Businesses and their counsel must be abreast of the regulatory changes to avoid the pitfalls as they maximize the investment's potentials.

Join a seasoned panel of thought leaders and professionals brought together by The Knowledge Group as they provide an in-depth discussion of the promises and perils of QOZ and QOF. Speakers will also present emerging trends and updates surrounding this topic and offer practical tips to leverage opportunities.

Key issues that will be covered in this course are:

  • Latest Trends and Updates in Opportunity Zones & Opportunity Funds
  • Emerging Critical Issues
  • Leveraging Opportunities
  • Practical Tips and Strategies
  • What Lies Ahead

 

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

Preview Podcast

Please click the podcast below to hear the speakers discuss the key topics for this webcast.

Faculty

Online CLE Opportunity Zone
Darryl Steinhause
Partner
DLA Piper
Online CLE Opportunity Zone
P. Quinn Moss
Partner
Orrick, Herrington & Sutcliffe LLP

Click Here to Read Additional Material

Online CLE Opportunity Zone

Darryl Steinhause, Partner
DLA Piper
  • Opportunities and challenges under OZ rules for Investment of Gains by Investors, including contributions in kind, dispositions of interest in QOF and reinvestment, Section 1231 gains and certain events that trigger inclusion of the gain without the QOF benefits
  • Opportunities and challenges under OZ rules in forming Commingled QOFs, including rules permitting 6-month grace period for newly contributed assets; interim dispositions, disposition of properties,12-mo reinvestment rules, incurrence of debt, promotional interests, permitted distributions and basis adjustments
  • Opportunities and challenges under OZ rules in investing in QOZBs that are Operating Businesses, including new safe harbors and guidance for non-financial assets, the 50% income tests and 70% tangible property test, leasing real and tangible property from related parties and use of intangible property
  • Opportunities and challenges for QOZBs focused on real estate development and rentals, including permitted activity and restrictions on activity (i.e., no Triple Net Leases) and treatment of land
  • Hypotheticals highlighting promise and peril until further guidance provided

P. Quinn Moss, Partner
Orrick, Herrington & Sutcliffe LLP

The Opportunity Zone (OZ) rules, including the October 2018 and April 2019 proposed regulations, provide significant guidance as to investment in and by Qualified Opportunity Funds (QOF), including investments in underlying Qualified OZ Businesses (QOZBs) that are primarily real estate businesses and/or are operating businesses. We plan to discuss the opportunities currently offered by the OZ rules as modified by the most recent regulations and also the key questions that remain.

  • Opportunities and challenges under OZ rules for Investment of Gains by Investors, including contributions in kind, dispositions of interest in QOF and reinvestment, and certain events that trigger inclusion of the gain without the QOF benefits
  • Opportunities and challenges under OZ rules in forming Commingled QOFs, including rules permitting 6-month grace period for newly contributed, assets; interim dispositions, 12-mo reinvestment rules, incurrence of debt, permitted distributions and basis adjustments
  • Opportunities and challenges under OZ rules in investing in QOZBs that are Operating Businesses, including new safe harbors and guidance for non-financial assets, the 50% income tests and 70% tangible property test, leasing real and tangible property from related parties and use of intangible property
  • Opportunities and challenges for QOZBs focused on real estate development and rentals, including permitted activity and restrictions on activity (i.e., no Triple Net Leases)
  • Hypotheticals highlighting promise and peril until further guidance provided

Online CLE Opportunity Zone

Online CLE Opportunity Zone

Darryl SteinhausePartnerDLA Piper

Darryl Steinhause is a partner in DLA Piper's Real Estate Capital Markets group.

Mr. Steinhause is an integral component of the real estate capital markets practice at DLA Piper. He is familiar with industry best practices and is well versed in the structuring and formation of a wide variety of real estate private equity funds, including those adopting a private REIT structure and the newly created Opportunity Zone Funds. A significant aspect of this representation involves the formation and structuring of sponsor ownership vehicles in a tax-efficient manner in order to maximize after-tax incentive payments to sponsors, their owners, and their employees.

With more than 35 years of experience in highly technical securities and tax transactions, Mr. Steinhause has structured securities offerings for a wide variety of significant clients across the country, acting as lead counsel on over 10 billion dollars of fund, debt, real estate investment trust (REIT), Delaware statutory trust (DST), Opportunity Zone Funds and other offerings. He has represented both sponsors and institutional investors in a variety of deal structures, including publicly registered transactions, private placements and institutional funds.

Online CLE Opportunity Zone

P. Quinn MossPartnerOrrick, Herrington & Sutcliffe LLP

Quinn Moss, is a corporate partner in the New York office of Orrick Herrington & Sutcliffe LLP, co-head of Orrick’s global Private Investment Funds Group, and on the leadership committees for Orrick’s Opportunity Zone initiative and Orrick’s Impact Finance and Investment Group. Quinn represents private investment fund sponsors (including impact funds) and institutional investors in private investment funds. Quinn received her B.A. from Harvard University, her J.D. from the Fordham School of Law and is admitted in New York.  She is a member of the SEC Working Group for the National Association of Public Plan Attorneys (NAPPA), a member and former Trustee of the American College of Investment Counsel (ACIC), a member of the Association of the Bar of the City of New York, and a director, corporate secretary and volunteer for High Water Women Foundation. Quinn has recently presented and moderated panels exploring Opportunity Zones opportunities, has frequently presented and moderated panels focusing on impact finance and investment, the negotiation of fund terms and the impact of regulation on funds, and also was lead author of “Fundraising Terms and Conditions: Legal Developments in Key Countries” published in Private Equity and Venture Capital – Regulation and Good Practice (Risk Books, 2014).

Online CLE Opportunity Zone

Course Level:
   Intermediate

Advance Preparation:
   Print and review course materials

Method Of Presentation:
   On-demand Webcast

Prerequisite:
   General knowledge of tax laws

Course Code:
   148094

NY Category of CLE Credit:
   Areas of Professional Practice

Total Credits:
    1.5 CLE

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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.

The Real Estate Capital Markets group of DLA Piper builds creative solutions for your business needs. Our interdisciplinary approach ensures the involvement of skilled practitioners to address the complexities of real estate securities. Our group’s experience acting as lead counsel on fund, REIT, DST, TIC and debt offerings, gives our clients an edge in capital markets transactions.

Website: https://www.dlapiper.com/

Orrick Herrington & Sutcliffe LLP is a leading global law firm with a particular focus on serving clients in the technology, energy and financial sectors. We are recognized worldwide for delivering the highest-quality, commercially oriented legal advice and fostering a culture of innovation and collaboration with our clients, among our lawyers and staff and within our communities. Founded in San Francisco a century and a half ago, Orrick today is named by Law360 as one of the "Global 20" leading firms. With approximately 1,100 lawyers across the United States, Europe and Asia, our platform offers clients a distinctive combination of local insight and consistent global quality across our key market locations.

Website: https://www.orrick.com

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