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Are there any Opportunity Zones in the Virgin Islands or other U.S. territories?

And if there are, do they differ from regular, on-shore OZs in any way?

  • Matthew Rappaport
    July 15, 2019

    Consult the official CDFI map to see whether the USVI or any other U.S. territory has Opportunity Zones, and if so, where they're located. These zones would not differ tax-wise from territorial OZs.

  • Neil Faden
    July 15, 2019

    There are Opportunity Zones in the Virgin Islands. believe there are more than a dozen of them, including zones in St. Croix and St. Thomas. Virtually all of Puerto Rico is an Opportunity Zone. It is a federal program, so it works the same way from a federal tax perspective, although the local law implications my vary and could impact whether it makes sense to use the program.

  • Blake Christian
    July 12, 2019

    Approximately 40% of the island is OZ eligible. The OZ program benefits apply the same to qualified investments into the U.S. Virgin Islands. You will need to watch out for local tax laws and potential international aspects of the investment. The QOF must also be formed as a U.S. domestic entity.

  • Matt Campbell
    July 12, 2019

    Yes, much of the island south of S. Thomas is in an opportunity zone. Virtually all of Puerto Rico is in a zone. Local tax law and filings would need to occur.

  • Donny Lucaj
    July 12, 2019

    Yes, there are Opportunity Zones in the U.S. Virgin Islands and other U.S. Territories. They operate in the same manner as on-shore OZs but there are some minor nuances in the tax law. For example: if a qualified opportunity zone fund is created in Puerto Rico, it can only invest in Puerto Rican opportunity zones. But if the fund is created on-shore it can invest in Puerto Rico opportunity zones as well as other opportunity zones. I'm not sure if the same goes for the U.S. Virgin Islands.

  • David LeGrand
    July 11, 2019

    This is the best I could find. "The proposed regulations further define a U.S. possession to mean any jurisdiction outside of the 50 States and the District of Columbia in which a designated qualified opportunity zone exists under section 1400Z-1. This definition may include the following U.S. territories: American Samoa, Guam, the Commonwealth of the Northern Mariana Islands, Puerto Rico, and the U.S. Virgin Islands. A complete list of designated qualified opportunity zones is found in Notice 2018-48, 2018-28 I.R.B. 9."

  • Kostas Poulakidas