White Paper

14 Pages
  • 14 Pages

Opportunity Zones: A Preliminary Examination


What qualifies as qualified opportunity zone property?

The TCJA made extraordinary changes to U.S. federal tax law which included a new tax regime relating to qualified opportunity zones to encourage private investment in distressed communities in the U.S. Investors that wish to defer capital gains recognized upon a sale or exchange of an asset to an unrelated1 party on or prior to December 31, 2026 can invest that gain in a Qualified Opportunity Fund (QOF), which in turn invests in so called “qualified opportunity zone property.” This white paper reviews the status of the Opportunity Zone program, tax benefits of investing in QOFs, and issues pertaining to sponsors and the formation of QOFs.



Lisa Brill

Lisa Brill

Shearman & Sterling LLP

  • Partner and co-head of the Hospitality, Leisure & Gaming Industry Group in the office of Shearman & Sterling LLP
  • Practice emphasizes all aspects of Real Estate, including acquisitions and dispositions, joint venture formations and financing transactions and has worked extensively representing both institutional investors and real estate operating companies in the investment, ownership and development of real estate
  • Represents lenders in different types of financing transactions, including mezzanine loans, construction loans, mortgage loans and hotel financings
  • Conducts regular seminars and workshops on numerous Real Estate subjects
  • Author of several publications related to the areas of Real Estate in publications in The Real Estate Finance Journal and Real Estate Finance & Investment
  • J.D. degree, Georgetown University; A.B. degree, Bowdoin College
  • Can be contacted at [email protected] or 212-848-4536
Michael Shulman

Michael Shulman

Shearman & Sterling LLP

  • Partner and Tax Team Leader in the office of Shearman & Sterling LLP
  • Practice emphasizes all aspects of Tax, including taxation of financial instruments, real estate transactions, and the formation and operations of hedge funds, private equity funds and regulated investment companies
  • Has wide-ranging experience in domestic and cross-border mergers, acquisitions and restructurings and has advised on numerous debt restructuring transactions
  • Author of several publications related to the areas of Tax
  • Chair of the Financial Transactions Committee of the American Bar Association
  • LL.M degree, New York University, School of Law; J.D. degree, Vanderbilt University; B.A. degree, with honors, University of Chicago
  • Can be contacted at [email protected] or 212-848-8080

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