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Qualified Opportunity Zones: Trust and Estate Planning Considerations and Advanced Techniques for Counsel

Tax Issues, Planning With Expanded Exemptions, Deferral of Gain Through Reinvestment, Using Trusts to Leverage Gifting, Clawbacks

Note: CPE credit is not offered on this program

Recording of a 90-minute CLE webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Tuesday, November 26, 2019

Recorded event now available

or call 1-800-926-7926

This CLE course will provide trust and estate counsel an in-depth analysis of planning techniques and opportunities with qualified opportunity zones (QOZs). The panel will discuss critical considerations for trust and estate planning with QOZs such as critical tax issues and methods to overcome them, planning techniques in light of expanded exemptions, the deferral of gain through reinvestment, using trusts to leverage gifting, treatment of partnership liabilities, and other matters of interest.


The QOZ provisions and qualified opportunity funds (QOF) under the new tax law provide trust and estate planning opportunities for investors and taxpayers. Grasping a complete understanding of complex tax rules and planning techniques can reduce current capital gains and defer recognition for investors, maximizing the preservation of their wealth under the new tax law.

Investments in QOFs provide for the deferral of capital gains and potentially no tax on any post-acquisition appreciation. Recent IRS regulations clarify the treatment of gifts of QOF interests to grantor trusts and GRATS, and gifts of interests in preferred partnerships. With careful planning, an investor can gift QOF interests without triggering immediate taxation of capital gains.

Recent IRS regulations also provide that the transfer of a qualifying investment to the taxpayer's estate or a distribution by the estate to the heirs would not trigger the inclusion of the deferred gain in gross income. Estate planners and tax counsel must be aware of crucial tax considerations and planning methods to ensure optimum tax and estate planning for investors.

Listen as our panel discusses essential considerations for trust and estate planning with QOZs, critical tax issues and methods to overcome them, deferral of gain techniques, use of trusts to leverage giftings, and other matters to ensure effective planning.



  1. Overview of QOZs
  2. Estate planning opportunities and key challenges
  3. Use of trusts and leveraging gifts
  4. Income tax planning issues and opportunities
  5. Best practices to avoid estate and income tax planning issues with QOZs


The panel will review these and other key issues:

  • What trust and estate planning opportunities do QOZs provide?
  • What are the estate planning tax issues and methods to overcome them?
  • How can trusts be used to leverage gifting about interest in QOZs?
  • How can you defer gain through reinvestments in QOZs?
  • How are partnership liabilities and distributions treated under current tax rules and proposed regulations?


Calderon, Ricardo
Ricardo (Rick) Calderon

Managing Director
MAS Advisors

Mr. Calderon is the Managing Director and Principal of MAS Advisors. He is a Director of Acadia Life Limited and its...  |  Read More

Levine Sanft, Andrea
Andrea L. Sanft

Executive Director
Morgan Stanley Private Wealth Management

Ms. Sanft is an Executive Director and Estate Planning Strategist in Morgan Stanley’s Private Wealth Management...  |  Read More

Lipoff, Lawrence
Lawrence M. Lipoff, CPA, TEP, CEBS


With more than 30 years of experience, Mr. Lipoff specializes in the delivery of domestic and international private...  |  Read More

Tarr, Alan
Alan J. Tarr

Partner and Chair, Tax Department
Loeb & Loeb

Mr. Tarr's practice focuses on tax planning for business transactions, including acquisitions and dispositions of...  |  Read More

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