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What are the rules regarding what can be in a Qualified Opportunity Fund?

For example, can it be a limited liability company?

  • Brad Cohen
    June 25, 2019

    LLC, partnership or stock in corporation.

  • Donny Lucaj
    June 18, 2019

    A fund can be a partnership or a corporation (and LLC would be acceptable).

  • Darci Congrove
    June 18, 2019

    A Qualified Opportunity Fund may invest directly in assets (like real estate), but more commonly it will invest in the stock of a corporate or a membership interest in an LLC. The business or real estate within the corporation or LLC must meet the definition of "qualified Opportunity Zone property."

  • Erik Kodesch
    June 12, 2019

    A QOF can be any entity treated as a corporation or partnership for tax purposes. This includes an S corporation and an LLC with more than one member. A single-member LLC would have to elect out if it’s default status as a disregarded entity to be treated as a corporation to be a QOF.

  • Blake Christian
    June 12, 2019

    Yes, the QOF can be either a C corp, S corp or partnership (including LLC with two members).

  • Maria De Los Angeles Rivera
    June 11, 2019

    An domestic entity treated as a corporation or a partnership for federal tax purposes may self-certify itself as a QOF as long as the requirements as to investment in Qualified Opportunity Zone Business Property are met. The certification is made via Form 8996.