IRC 1400Z Qualified Opportunity Zones for Individual Investors: Tax Deferral and Reduction Opportunities
Claiming Capital Gains Tax Mitigation, Basis Step-Up on a Qualified Opportunity Fund Investment and Disposition
Note: CLE credit is not offered on this program
Recording of a 110-minute CPE webinar with Q&A
This course will provide tax advisers with a practical guide to understanding the tax incentives made available to investors under Internal Revenue Code Section 1400Z-2. The panel will discuss the mechanics of Code Section 1400Z-2 and the proposed regulations issued in October 2018 and April 2019. We will discuss how to qualify for tax benefits by investing in a qualified opportunity fund (QOF), the requirements to create and maintain QOFs and qualified opportunity zone (QOZ) businesses, and the key areas of law that remain uncertain.
Outline
- Opportunity zone overview
- Policy and current political considerations
- Qualified opportunity fund structures
- Opportunity zone investment requirements and mechanics
- Real-world examples and issues
- Incentive comparison-- “Q-ville”
- Filing and documentation requirements
Benefits
The panel will review these and other key issues:
- What are QOZs and the eligibility requirements under Code Section 1400Z-1?
- What are QOFs and QOZ businesses?
- How taxpayers can form and operate their own QOF and/or QOZ business.
- How taxpayers can ensure deferral, reduction and/or elimination of capital gains tax liability.
- Recent IRS guidance on gain deferral and the how to satisfy the various "substantially all" asset and operational requirements.
Faculty
Christopher A. Karachale
Partner
Hanson Bridgett
Mr. Karachale advises individuals and business entities on a broad range of tax planning and tax controversy matters.... | Read More
Mr. Karachale advises individuals and business entities on a broad range of tax planning and tax controversy matters. He has written extensively on QSBS issues. He counsels taxpayers on employee benefits and executive compensation issues, including deferred compensation and Section 409A. He assists clients with international tax compliance, including voluntary disclosures and related planning matters. He represents individuals and an array of business entities in controversy matters before the IRS and California state tax authorities.
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Jeffrey C. Messerschmidt, CPA
Partner
Navolio & Tallman
Mr. Messerschmidt works closely with the firm’s business and individual clients across a range of industries,... | Read More
Mr. Messerschmidt works closely with the firm’s business and individual clients across a range of industries, including real estate, venture capital, private equity, hedge funds, start-up companies, privately-held businesses, and breweries. Within these industries, he manages and handles strategic tax planning and consulting as well as all facets of income, trust, and estate tax compliance. Mr. Messerschmidt has particular emphases in executive compensation, qualified small business stock transactions, taxation of complex financial instruments, wealth transfer, trust accounting and taxation, partnership taxation and allocations, foreign reporting requirements, and tax minimization.
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Daren R. Shaver
Partner
Hanson Bridgett
Mr. Shaver is a transactional tax attorney, helping clients achieve their objectives in a practical and tax-efficient... | Read More
Mr. Shaver is a transactional tax attorney, helping clients achieve their objectives in a practical and tax-efficient manner. He has experience with matters spanning areas such as fund formation, tax credits, real estate, venture capital, partnerships, and tax exempt entities--including federal and state income tax matters. Prior to joining the firm, Mr. Shaver was affiliated with several leading international and regional law firms.
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