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How should I handle a partnership when it comes to my Qualified Opportunity Fund?

I have a Qualified Opportunity Fund LLC and I want to invest in a partnership which is buying land for development in an opportunity zone. I will have an equity interest in it with qualified funds. But other partners do not have qualified funds and are not interested in it. Question 1. Does this partnership needs to be registered as an Opportunity zone partnership and will I need to fill out IRS form 8996? Question 2. If we do take a loan to develop the property with my QOF, will there still there be the same percentage equity share in the original partnership with no dilution if no new partners are accepted in it? Question 3. Do I have to take the title in my QOF name or my name?


Answers
  • Matthew Rappaport
    February 10, 2022

    1) Yes, you'll need Form 8996. 2) I don’t see why not. 3) The QOF's name, though we typically recommend a two-tiered structure in which you'd form a QOZB and take title in either the QOZB's name or a single-member LLC subsidiary of the QOZB.

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