Opportunity Zone Benefits; Nuts and Bolts; and Loose or Missing Screws

The Tax Cuts and Jobs Act of 2017 created a new tax incentive, the Qualified Opportunity Fund (QOF), designed to encourage long-term investment in low income communities. The QOF has stirred substantial investor excitement, but the lack of guidance before the issuance of the Proposed Regulations has frustrated the investment bankers and syndicators. We examine the incentive available to taxpayers who invest in a QOF as well as the detailed requirements found in the first set of Proposed Regulations.