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Opportunity Zones Under Tax Reform

 

Gain an in-depth understanding of the significant changes made to the Tax Cuts and Jobs Act.

The Tax Cuts and Jobs Act of 2017 (the 'Act') made significant changes to U.S. federal tax law. One of these changes was the establishment of a new tax regime relating to qualified opportunity zones ('Opportunity Zones') under Sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code of 1986, as amended (the 'Code'), to encourage private investment in distressed communities throughout the United States. Investors that wish to defer capital gains recognized upon a sale or exchange of an asset to an unrelated party on or prior to December 31, 2026 can invest that gain in a Qualified Opportunity Fund (QOF), which in turn invests in socalled 'qualified opportunity zone property.' This topic will discuss the current status of the Opportunity Zone program, the tax benefits associated with investing in QOFs, what qualifies as qualified opportunity zone property and issues relevant to sponsors in connection with the formation of QOFs.

Agenda

Faculty

Michael Shulman

Michael Shulman

Shearman & Sterling LLP

  • Partner and Tax Team Leader in the office of Shearman & Sterling LLP
  • Practice emphasizes all aspects of Tax, including taxation of financial instruments, real estate transactions, and the formation and operations of hedge funds, private equity funds and regulated investment companies
  • Has wide-ranging experience in domestic and cross-border mergers, acquisitions and restructurings and has advised on numerous debt restructuring transactions
  • Author of several publications related to the areas of Tax
  • Chair of the Financial Transactions Committee of the American Bar Association
  • LL.M degree, New York University, School of Law; J.D. degree, Vanderbilt University; B.A. degree, with honors, University of Chicago
  • Can be contacted at [email protected] or 212-848-8080
Lisa Brill

Lisa Brill

Shearman & Sterling LLP

  • Partner and co-head of the Hospitality, Leisure & Gaming Industry Group in the office of Shearman & Sterling LLP
  • Practice emphasizes all aspects of Real Estate, including acquisitions and dispositions, joint venture formations and financing transactions and has worked extensively representing both institutional investors and real estate operating companies in the investment, ownership and development of real estate
  • Represents lenders in different types of financing transactions, including mezzanine loans, construction loans, mortgage loans and hotel financings
  • Conducts regular seminars and workshops on numerous Real Estate subjects
  • Author of several publications related to the areas of Real Estate in publications in The Real Estate Finance Journal and Real Estate Finance & Investment
  • J.D. degree, Georgetown University; A.B. degree, Bowdoin College
  • Can be contacted at [email protected] or 212-848-4536

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