What is the best way to structure a qualified opportunity fund?
Qualified opportunity funds need to be classified for tax purposes as a corporation or a partnership. The proposed regulations make it clear that a limited liability company is eligible for treatment as a QOF and they may be joint ventures, club deals, or funds formed for one investor (“fund of one”). A QOF may also hold REIT stock issued to the QOF by a REIT that is a qualified opportunity zone business, and a QOF may itself be a REIT. This video reviews entity types, securities laws, investment limitations and terms of a qualified opportunity fund.
Agenda
Faculty
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
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
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