This two-hour program examines the new federal opportunity zone regime applicable to qualified opportunity zone (QOZ) investments made beginning in 2027, with particular emphasis on the tax planning, structuring, and compliance issues affecting taxpayers and their advisors. Designed for attorneys, accountants, financial advisors, and other tax professionals, the course explores the updated statutory framework and its practical implications for investors, fund sponsors, and businesses operating in designated opportunity zones. A significant portion of the course is devoted to the federal income tax consequences of post-2026 opportunity zone investments. The program will also discuss the mandatory recognition of deferred gain for pre-2027 opportunity zone investments in 2026.
Learning Objectives
- Explain the statutory framework governing opportunity zone investments beginning in 2027
- Identify the qualification requirements for qualified opportunity funds and qualified opportunity zone businesses under the revised rules
- Analyze the federal income tax consequences of new opportunity zone investments throughout the investment lifecycle
- Recognize reporting obligations, compliance requirements, and potential audit issues
- Evaluate tax planning opportunities and structuring considerations for investors, fund sponsors, and operating businesses under the new 2027 opportunity zone regime
- Apply current legislative and regulatory guidance to advise clients regarding post-2026 opportunity zone investments
Major Topics
- The rules governing gain deferral, basis adjustments, holding period requirements, recognition events, and the exclusion of post-investment appreciation
- Mandatory recognition of deferred gain for pre-2027 opportunity zone investments in 2026
- The mechanics of qualifying for opportunity zone tax benefits
- Rules governing eligible capital gains
- Qualified opportunity funds, qualified opportunity zone businesses, and the applicable asset and business qualification tests
- Federal income tax consequences associated with opportunity zone investments
- Selected state tax conformity issues, planning opportunities, and challenges arising from differing state treatment of opportunity zone incentives
