Qualified Opportunity Funds: Benefits, Opportunities and Challenges in 2019
The Opportunity Zones (OZ) investment tool is regarded as one of the most noteworthy concepts that resulted from the 2017 Tax Act. Through an investment vehicle known as Opportunity Fund, investors are able to infuse capital on qualified OZ and, in return, the government provides them with substantial tax deferrals. However, despite the tax benefits offered under OZ, potential risks and challenges cannot be ignored. Before one invests in OZ, in-depth knowledge of the deal’s fundamentals and pitfalls is imperative.
Join a panel of key thought leaders and professionals assembled by The Knowledge Group as they provide the audience with a comprehensive analysis of the benefits, opportunities, and challenges presented by a Qualified Opportunity Fund investment. The speakers will also dive into the recent trends and developments in this new business landscape.
Some of the major topics that will be covered in this course are:
- Qualified Opportunity Fund – Latest Trends and Developments
- Leveraging Opportunities
- Risk Issues and Challenges
- Best Practices and Strategies
- What Lies Ahead
Matthew J. Schiller, Partner
Greenbaum, Rowe, Smith & Davis LLP
- A brief history of the Opportunity Zone program
- The tax benefits and statutory framework of the Opportunity Zone program,
- Structuring Opportunity Zone Funds and Opportunity Zone businesses
- Understanding the 50% gross income requirement for Qualified Opportunity Zone Businesses
- Satisfying the “substantially all” requirements
- The applicability of the original use/substantial improvement tests
- Working capital concerns
- Leasing in opportunity zones
Stephen Wilson, Of Counsel
- Basic guidance now exists for new “QOZ businesses” (going businesses, not real estate)
- New Regs prohibit QOZ benefits for “carried interests”
- New Regs offer relief in most instances when a QOZ investor dies
- New Regs provide a “savings clause” through qualifying reinvestment if a QOZ investment is sold prematurely.
Who Should Attend:
- Business Owners
- Investment Advisors
- Fund Managers
- Financial Management Officers
- Top Level Executives
- Tax Professionals
- Public and Private Companies
- Other Related/Interested Professionals and Organizations
Steve Wilson has 45 years of continuous experience in transactional real estate law and related business issues. He also has substantial experience in corporate and general business law. He has held the esteemed Martindale-Hubbell "AV" (“preeminent”) peer designation for many years.
In the superheated West Coast real estate environment, he augments his technical knowledge by providing the business judgment and perspective that a seasoned institutional real estate executive would provide. Much of his current professional focus is on complex, value-added urban mixed-use projects and joint ventures, with recent focus on project planning in Qualified Opportunity Zones. A related longtime focus is assisting nonprofit or charitable organizations (including religious organizations) seeking to monetize their land holdings in a way which incorporates a charitable or public benefit. Steve’s clients routinely comment that he is "their other partner".
Other significant capabilities include real estate tax issues, entity formation/asset management for portfolio owners, restructuring and securitization of holdings, entitlement work, purchases and sales, commercial leasing and title matters. Many clients are offshore investors who benefit greatly from his guidance. Steve has been an expert witness in two recent, significant jury trials involving real estate issues.
Steve has traveled widely on business in Asia, and for 10 years led post-Perestroika humanitarian orphanage support work in the Ryazan region of CIS. His humanitarian endeavors have also included Africa and South America. In 2013, he lectured Chambers of Commerce throughout Indonesia on trade with the US. In 2017, he was a member of the San Francisco Mayor’s economic and trade delegation to Vietnam.
Steve Wilson has 45 years of continuous experience in transactional real estate law and related business issues. He also has …
Matthew J. Schiller is a partner in the Real Estate and Redevelopment & Land Use Departments at Greenbaum, Rowe, Smith & Davis LLP, where he concentrates his practice in commercial real estate law. Mr. Schiller’s work encompasses a wide array of commercial real estate transactional, zoning, redevelopment, taxation and litigation matters throughout New Jersey, New York and Connecticut. His transactional experience includes the acquisition, disposition, leasing and management of office, retail, and industrial properties. In addition, Mr. Schiller's practice includes seeking municipal and state land use approvals for commercial and residential developments. He also represents special servicers in connection with distressed real estate assets, including loan workouts and modifications, foreclosures, deeds in lieu of foreclosure, REO sales and loan sales. Mr. Schiller is a frequent author and lecturer on Qualified Opportunity Zones.
Matthew J. Schiller is a partner in the Real Estate and Redevelopment & Land Use Departments at Greenbaum, Rowe, Smith …
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Method of Presentation:
On-demand Webcast (CLE); Group-Internet Based
Experience in tax laws
NY Category of CLE Credit:
Areas of Professional Practice
NASBA Field of Study:
Taxes - Technical
1.0 CPE (Not eligible for QAS (On-demand) CPE credits)
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Founded over 100 years ago, Withers is a leading international law firm for global businesses, their equity and debt stakeholders, and the executives who manage them. The firm is one of the largest tax law firms in the world and consists of over 160 partners supported by more than 1,000 people across 18 strategically located international offices.
Our Real Estate practice represents investors, developers, landowners, banks, institutions and non-profit organizations who are buying, selling, developing and investing in real estate in Europe, Asia (including Australia, China and Singapore), the Americas (including the Caribbean) and worldwide. We have experience working with a variety of investment vehicles, from open-ended investment companies to limited partnerships, unit trusts and REITs and deal with many major offshore fund jurisdictions. With experience in various aspects of real estate development--from obtaining land use approvals to negotiating design and construction agreements--we advise both landowners and developers in relation to real estate development.
We have completed commercial, residential and non-profit deals for some of the most prominent individuals and institutions in the world. Whether we’re advising a tenth-generation landowner in England, financing an international school in its expansion in Asia, helping a fund acquire a resort in Australia or structuring an investment in a mixed-use development in San Francisco, our team are discreet, cost-conscious and forward thinking, spotting potential pitfalls before anyone else.
About Greenbaum, Rowe, Smith & Davis LLP
Greenbaum, Rowe, Smith & Davis LLP is a multi-practice law firm serving local, regional and national clients. As one of New Jersey’s leading law firms, the firm brings diverse and comprehensive expertise to the representation of both businesses and individuals. For over 100 years, the firm has earned the trust and loyalty of clients by providing sophisticated, creative and cost-effective representation through collaborative teamwork, proactive legal strategies, attention to detail and relationship-oriented service.