Investments in Qualified Opportunity Zones (Portfolio 598)

Description

Tax Management Portfolio Investments in Qualified Opportunity Zones, No. 598, provides best-in-class analysis of all aspects of the opportunity zone program, which provides significant tax incentives for investment of deferred capital gain into qualified opportunity zones (QOZs). The portfolio provides complete coverage of qualifying investments in qualified opportunity funds (QOFs), including the definition of an eligible taxpayer, eligible gain, and eligible interests, as well as the 180-day investment period rules. It includes detailed discussions of all of the definitional and operational requirements applicable to QOFs, qualified opportunity zone property (QOZP), qualified opportunity zone business property (QOZBP), and qualified opportunity zone businesses (QOZBs). It also discusses the basis rules applicable to OZ investments, the rules applicable to sales of OZ assets, and consolidated return rules relevant to OZ investments.

Table of Contents

• I. The Opportunity Zone Program – Background and Overview
• II. Qualifying Investment in a QOF
• III. Qualified Opportunity Funds
• IV. Qualified Opportunity Zone Property
• V. Qualified Opportunity Zone Business Property
• VI. Qualified Opportunity Zone Business
• VII. Basis Rules
• VIII. Recognition of Deferred Gain
• IX. QOF Qualifying Investments Held for at Least 10 Years
• X. Anti-Abuse Rules
• XI. Special Rules Applicable to Consolidated Groups