Novogradac & Co: A Deeper Dive into the Second Tranche of Opportunity Zones Regulations: Benefits and Pitfalls

Novogradac and Company released Part II of its analysis of the second tranche of Opportunity Zones regulations. In addition to the issues discussed in Part I, Michael Novogradac covers some of the issues getting the most attention including:

  • the greater predictability of the tax treatment of distributions of refinance proceeds by qualified opportunity fund (QOF) partnerships;
  • the ability to exclude gain from certain QOF partnership asset sales;
  • clarifications regarding valuing a QOF interest in 2026 as well as for QOF investments held for 10 years;
  • the potential for the creation of a secondary market for interests in QOF investments; and
  • the possible use of feeder partnerships.