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How can I form a QOZB/QOF to acquire a non-US tech startup?

I plan to form a QOZB/QOF to acquire a non-USA tech startup. The QOZB will be fully own by the acquired startup (a disregarded entity subsidiary?) and I will move management, sales, service, installations, regulatory, and a part of R&D functions to QOZB. I will initially treat the acquired startup as one of many QOZB vendors and will reduce the sizes and functions of the acquired startup. Is this doable with OZ consideration?


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  • Matthew Rappaport
    December 07, 2021

    Don't think this is doable because a Qualified Opportunity Zone Business needs to draw at least 50% of its income from Opportunity Zones, and I don't think a non-US tech startup can accomplish that unless it has very substantial US operations.

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