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How can my company qualify as a QOZB if I hire staff that work remotely outside of the zone?

I know that a QOZB has to meet the active trade or business requirement test and has four safe harbors. Could the property and management safe harbor extend to a software company that has coders and salespeople outside of the zone? The company plans to start in the zone but will need to use remote coders and salespeople, who will be supervised by the management team from the HQ in a QOZ. Will this suffice to meet the safe harbor?


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  • Matthew Rappaport
    July 14, 2020

    This sounds viable. You'll need to work closely with your advisors to get it right, but it seems like a real path forward. I'd be careful not to have a disproportionately high amount of employees outside the QOZ, meaning a very small "management team" supervising a very large number of other employees would not look great upon audit.

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