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How do partnership tax rules apply if a Qualified Opportunity Fund is structured as a partnership for federal tax purposes?

What are other beneficial ways to structure a QOF?


Answers
  • Matthew Rappaport
    May 12, 2021

    The partnership tax rules apply as normal, except as the OZ regulations modify them (which is not that much, comparatively speaking). You can structure a QOF as a corporation as well, which could be beneficial for operating businesses, but it is never beneficial for real estate unless you plan on being a REIT (which is itself a corporation). A QOF cannot be a sole proprietorship or disregarded entity, and it cannot be a trust or estate.

  • Maria De Los Angeles Rivera
    June 04, 2021

    The partnership tax rules will apply in the same manner to a QOF as to any other partnership.

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