Many investors are biting at the chops, or at the least tempted, to sow for the harvest of enticing new Qualified Opportunity Zone (QOZ) tax breaks. Beyond the economic risk of investing in property in distressed areas, the problem is the QOZ statutes and regs don't provide enough certainty to give would-be investors the comfort to give it a go.

On 04/17/19, Treasury dropped into our laps the second batch of long awaited QOZ proposed regulations. This is very good news. But, the bad news is we did not get all the news we needed. Either way, investors need answers today.

Learning Objectives

• To learn the backstory: QOZ statutory scheme and first round of proposed regs (Act 1);
  
• To learn all-new round 2 of proposed regs (Act 2)
  
• To learn what Treasury and IRS have yet to tell us (Act 3)
  
• Working examples of all 3 QOZ tax breaks
  
• Qualified Opportunity Funds (QOFs) and Qualified Opportunity Fund Businesses (QZOBs) - Who's (what's) in, who's (what's) out?
  
• Structure, deadlines, compliance obligations and penalties
  
• Whether the entity (QOF) or its assets must be sold to obtain exclusion
  
• How do the rules work with tiered partnerships?
  
• Like kind exchange interplay or, by contrast, as an alternative approach
  
• Estate and gift planning interplay
  
• Timing, timing, timing and timing

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