Structuring Investment Funds for Qualified Opportunity Zones: Maximizing Tax Benefits and Preserving Flexibility
Recording of a 90-minute premium CLE/CPE webinar with Q&A
This CLE/CPE webinar will examine the tax and operational issues counsel must consider when structuring a "qualified opportunity fund" for investment in a qualified opportunity zone. The panel discussion will include the tax ramifications of capital structure, advantages of using a portfolio company vs. a one-off entity to make investments, exit strategies, and how sister companies can be utilized to make investments outside an opportunity zone.
Outline
- Qualified opportunity zones: New tax incentives for investment
- Qualified opportunity funds: Investment parameters
- Structural considerations
- Capital investment
- Capital structure
- Portfolio company vs. direct investment
- Doing business outside of an opportunity zone
- Exit strategies
Benefits
The panel will review these and other noteworthy topics:
- What is a qualified opportunity fund and what are the investment parameters for taking advantage of the new tax exemptions?
- When should a QOF consider a portfolio structure as opposed to making a direct investment in a qualified opportunity zone business?
- Are there circumstances under which a QOF can engage in business outside an opportunity zone? How should that be arranged?
- What are the primary concerns in exiting a QOF investment?
Faculty

Molly R. Bryson
Partner
Ballard Spahr
Ms. Bryson is Team Leader of Ballard Spahr's Tax Credits Team. She focuses her practice on using federal and state... | Read More
Ms. Bryson is Team Leader of Ballard Spahr's Tax Credits Team. She focuses her practice on using federal and state tax credits to finance affordable housing, businesses in low-income communities, historic preservation, and solar energy throughout the U.S. and its territories.
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Wendi L. Kotzen
Partner
Ballard Spahr
Ms. Kotzen is the Co-Practice Leader of Ballard Spahr's Tax Group. She advises clients on the taxation of all types... | Read More
Ms. Kotzen is the Co-Practice Leader of Ballard Spahr's Tax Group. She advises clients on the taxation of all types of real estate transactions, has an extensive background in Pennsylvania and Philadelphia realty transfer tax planning, and advises clients on mergers and acquisitions. Ms. Kotzen is also experienced working with REITs; real estate partnerships (both for developers and investors); leasing transactions, including sale-leasebacks; Pennsylvania state tax incentives; and structuring like-kind exchanges (forward, reverse, and TIC exchanges).
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Sara A. McCormick
Atty
Ballard Spahr
Ms. McCormick concentrates on a variety of commercial real estate matters, including all phases of leasing,... | Read More
Ms. McCormick concentrates on a variety of commercial real estate matters, including all phases of leasing, acquisitions, dispositions, development transactions, joint ventures and fund formation, and investments.
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