Structuring A Qualified Opportunity Zone Fund—What You Need To Know

Since the enactment of the Opportunity Zone program over a year ago, the focus has been on gaining a better understanding of the workings of the program and its various applications. While the education curve has been demanding, it has not deterred taxpayers from taking advantage of the program. Qualified opportunity zone funds are now springing up everywhere, chasing the reported $6.2 trillion of unrealized gains for investment in one or more of the 8,700 certified opportunity zones. From the perspective of Qualified Opportunity Zone Funds, attracting capital is now their number one priority. Regardless of whether the fund is established to attract large institutional capital or a small group of wealthy local investors, securing capital will depend, in large part, on the legal structure of the fund, as well as navigating the regulatory, tax, and securities requirements of the Opportunity Zone associated with selling securities.