Qualified Opportunity Funds: Navigating Implications for Real Estate and Investors
The Tax Cut and Jobs Act authorized each governor to designate certain census tracts as “Qualified Opportunity Zones” (“QOZs”). Taxpayers realizing capital gains after December 31, 2018 can invest the cash realized from those events in a Qualified Opportunity Fund (“QOF”) for investment in a QOZ and take advantage of tax benefits, including deferral and partial reduction of their initial capital gain and complete avoidance of capital gain upon sale of the qualified asset. These benefits are subject to a myriad of rules, and companies must still be wary of the evolving tax regulations and other guidance.
Join a panel of key thought leaders and professionals assembled by The Knowledge Group as they provide the audience with an in-depth analysis of the implications of QO Fund for real estates and investors. Speakers will also discuss best practices to overcome challenges while maximizing opportunities.
This LIVE Webcast will discuss the following key provisions:
- Qualified Opportunity Funds: An Overview
- Requirements and Tax Considerations
- Leveraging Opportunities
- Legal and Economic Risk Issues and Challenges
- 2019 Outlook
Withers Bergman LLP
- Key deadline dates and how they interrelate;
- Minimum investment requirements and how they are calculated;
- “Hot buttons” in preparing an application for entitlements;
- Key terms for an LLC operating agreement (or LP agreement or shareholders agreement); and,
- Unpacking the “90% test” and the “70% test
Harris Beach PLLC
- QOZB Requirements
- Working Capital Safe harbor
- Revenue Ruling 2018-29
Archer & Greiner P.C.
- Benefits Available Through Opportunity Funds Not Available Through 1031 Exchanges
- Benefits Available Through 1031 Exchanges Not Available Through Opportunity Funds
- Non-tax considerations for choosing between the two
Who Should Attend:
- Business Managers
- Business Analysts
- Executive Board Members
- Business Development Managers
- Fund Managers
- Investment Advisers
- Financial Management Officers
- Tax Advisers
- Tax Consultants
- Other Related/Interested Professionals
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 …
Ms. Zaffram negotiates and drafts a broad range of corporate and transactional documents, including business contracts, software license agreements, consulting agreements and nondisclosure agreements.
Ms. Zaffram represents clients in federal and New York state tax disputes from the audit level through the appellate process with respect to controversies involving taxes such as business tax, personal income tax, and sales and use tax. She assists companies in obtaining tax savings through transactions with industrial development agencies, and consults with clients to obtain tax savings through the New York State Brownfield Cleanup Program. In connection with her economic development practice, Pietra provides counsel to clients regarding the federal Opportunity Zones program.
Additionally, Ms. Zaffram conducts corporate investigations, including those involving financial components and compliance issues arising across numerous states. Her investigative experience involves not only internal investigations, but also investigations conducted in the light of external components, such as government compliance and enforcement, which involves a detailed understanding and application of complex accounting principles, and the intersection of such principles with corporate financial statements.
Ms. Zaffram negotiates and drafts a broad range of corporate and transactional documents, including business contracts, software license agreements, consulting …
Jay was originally trained as a commercial litigator, handling a broad spectrum of matters concentrated on sophisticated mortgage lending, lease and contract disputes, but also including litigation over the ability of coop owners to resell their units as if they were condominiums and various lender liability issues.
In December 1985, when an imminent change in the Tax Code resulted in a tidal wave of real estate closings, Jay refocused his practice from litigation to transactional work. His practical experience, creativity and expertise is in demand by both lenders and borrowers in commercial real estate transactions. His clients include global, regional and local businesses and institutions, healthcare professionals, and individuals seeking to buy or sell property or form new business entities. His litigation background has enabled him to extend his real estate practice beyond the closing table and handle a variety of tax assessment, land use and condemnation cases as well. Jay’s training as a litigator has proved invaluable to clients by enabling him to negotiate and draft documents that are both understandable and enforceable. Should negotiations fail, he is well-equipped to evaluate and implement the most practical means of enforcing his client’s rights.
Jay was originally trained as a commercial litigator, handling a broad spectrum of matters concentrated on sophisticated mortgage lending, lease …
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Method of Presentation:
Experience in tax laws
NY Category of CLE Credit:
Areas of Professional Practice
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About Withers Bergman LLP
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.
Website: https:// www.withersworldwide.com
About Harris Beach PLLC
Founded in 1856, Harris Beach and its subsidiaries provide a full range of legal and professional services for clients across New York state, as well as nationally and internationally. Harris Beach is among the country’s top law firms according to The National Law Journal and ranks as a BTI Elite law firm based on in-depth interviews of more than 600 corporate counsel at the world’s largest and most influential companies. Clients include Fortune 100 corporations, privately-held companies, emerging businesses, public sector entities, not-for-profit organizations and individuals. Principal industries Harris Beach represents include education, energy, financial, food and beverage, health care, insurance, manufacturing, medical and life sciences, real estate developers, science and technology, veterinary medicine, and state and local governments and authorities. The firm’s more than 220 lawyers practice among offices throughout New York state in Albany, Buffalo, Ithaca, Melville, New York City, Rochester, Saratoga Springs, Syracuse, Uniondale and White Plains, as well as in New Haven, Connecticut and Newark, New Jersey.
About Archer & Greiner P.C.
Archer & Greiner, P.C. is a full-service regional law firm with more than 175 lawyers and eight offices. The firm has been serving Fortune 100 clients, small to medium-sized businesses and individuals for 90 years. Each office provides full-service litigation and transactional capabilities in nearly every area of law, including corporate, estate & trust, family & matrimonial, labor & employment, litigation, medical & personal injury, and real estate services. For more information, visit www.archerlaw.com.