InfO-Zone blog

Recent Opportunity Zone Guidance Gives Developers a Shot In the Arm

Posted by John Balboni on Nov 9, 2018 3:28:47 PM
Clarification on Working Capital, Substantial Improvement and Use of Leverage will Drive Investment Activity
Developers  intuitively understood the powerful nature of the new Opportunity Zone legislation, but their enthusiasm was hampered without further guidance. The answer to their calls for clarity came on October 19 th   when the Treasury Department issued proposed regulations, as well as Revenue Ruling 2018-29. Developers quickly recognized that the overall tenor of the newly issued guidance is "investor-friendly" and speaks to an overall theme of driving unbridled economic activity to the targeted opportunity zones. Specifically, three key points stand out to accelerate the flow of investment into Opportunity Zones, namely (i) flexible timing to deploy capital; (ii) a less-restrictive test on how measure substantial improvement; and (iii) making use of leverage to maximize development.
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Topics: Opportunity Zones, Qualified Opportunity Funds, Real Estate Finance, Real Estate Development, Affordable Housing, Real Estate Investment

Structuring Opportunity Zone Funds

Posted by Dan Ryan on Oct 26, 2018 4:38:32 PM

The Opportunity Zones Program created by the U.S. Tax Cut and Jobs Act of 2017 (the "OZone Program") and the first wave of proposed regulations issued by the Treasury Department on October 19, 2018 (the "Regulations") have been designed to generate economic activity in low-income urban and rural communities. Sullivan & Worcester’s Opportunity Zones Practice Group has analyzed the OZone Program and Regulations and has successfully structured multiple Qualified Opportunity Funds ("QOFs") with an anticipated aggregate capital raise of nearly $600 million.

As we and our clients continue to develop innovative QOF structures, we will provide a series of advisories that highlight specific structuring elements that are consistent with the OZone Program and the Regulations.

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Topics: capital gains, Opportunity Zones, Qualified Opportunity Funds, QOF


About the Blog

Sullivan's InfO-Zone blog features insight and analysis about Opportunity Zones, written by our multi-disciplinary team of lawyers from our Tax, Real Estate, Affordable Housing and Corporate practice groups. 

The material on this site is for general information only and is not legal advice. No liability is accepted for any loss or damage which may result from reliance on it. Always consult a qualified lawyer about a specific legal problem.




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