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How can take advantage of Opportunity Zones while investing in the growing trend of urban e-grocery startups and mini-fulfillment centers?


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  • Michael O'Mara
    September 07, 2021

    First, you need to identify current Opportunity Zones where you believe this business can succeed which requires macro/micro feasibility analysis. Secondly, you have to set up your business up as an Opportunity Zone Fund.

  • Matthew Rappaport
    September 05, 2021

    These are fair game to fund through Opportunity Zone vehicles, so have at it. As long as you comply with the OZ program's rules and regulations, you should be good to go.

  • Marko Belej
    September 03, 2021

    Urban e-grocery startups and mini fulfillment centers located in an Opportunity Zone (OZ) should be able to qualify as qualified opportunity zone businesses, like any other business. The one issue particular to these businesses is that they (presumably) might make deliveries outside of the OZ, and a Qualified Opportunity Zone Business (QOZB) has to derive at least 50% of its income from an active trade or business in the OZ. The regulations provide four different sets of criteria by which a business may satisfy this test. Perhaps the most applicable set is that the tangible property of the business is located in the OZ and the management or operational functions are necessary for generation of at least 50% of the gross income. So even though deliveries may occur outside the OZ, the activities at the grocery start-up or fulfillment center located in the OZ may be sufficient. The regulations provide the following example of a landscaping business that appears analogous: "A landscaping business has its headquarters in a qualified opportunity zone, its officers and employees manage the daily operations of the business (inside and outside the qualified opportunity zone) from its headquarters, and all its equipment and supplies are stored in the headquarters facilities. The activities occurring and the storage of equipment and supplies in the qualified opportunity zone are, taken together, necessary for the generation of the income of the business."

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