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Do partnership tax rules apply in an QOZF?

If an OZ fund is structured as a partnership, do partnership tax rules still apply?


Answers
  • Brad Cohen
    September 22, 2020

    Yes.

  • Matthew Rappaport
    September 22, 2020

    Yes, they do, with the small exceptions or modifications provided in the OZ regulations.

  • Valerie Grunduski
    November 16, 2020

    Yes and it is very important to understand the treatment of partnership losses in a QOF where you may have no tax basis until 2026.

  • Matt Campbell
    September 22, 2020

    Yes, if the QOF is established as a partnership or LLC taxed as a partnership.

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