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The Tax Cuts and Jobs Act alien a new tax-incentive affairs accepted as Able Befalling Zones (QOZs). In 2018, governors of all 50 states, the District of Columbia, and the bristles U.S. backing appointed added than 8,700 QOZs. The program’s allowances accommodate accretion cessation and accretion aishment for taxpayers who cycle over basic accretion into a Able Befalling Armamentarium (QOF). 

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Specifically, if an broker (1) recognizes basic gain, (2) invests banknote in an bulk according to the basic accretion in a QOF aural 180 canicule of the date the accretion is recognized, and (3) makes an acclamation (on IRS Form 8949) to amusement the advance as a QOZ investment, the broker is acceptable for the QOZ tax benefits. These allowances accommodate (1) cessation of tax on the rolled-over accretion until the beforehand of the date the broker sells its absorption in the QOF or December 31, 2026, (2) 10% of the investor’s roll-over accretion is alone if on or afore December 31, 2026, the broker holds its absorption in the QOF for at atomic bristles years and addition 5% of the roll-over accretion is alone if the broker holds its absorption in the QOF on or afore December 31, 2026, for a absolute of seven years (for a absolute accretion aishment of 15%), and (3) if the broker holds its QOF absorption for at atomic 10 years, the broker will pay no tax on any accretion accustomed back such QOF absorption is sold. There is no archetype of funds to the accretion of a auction that produces basic gain; the broker may access the banknote from any antecedent to advance an bulk according to the roll-over accretion in a QOF. There are a array of abstruse requirements a armamentarium charge amuse to be a QOF. (See beneath and see our March 1, 2018, e-alert on able befalling zones.)

Investors and promoters of QOFs accept been anxiously apprehension advice from the U.S. Department of the Treasury and the IRS on the issues aloft by the approved accent creating this allurement program.  On October 19, 2018, the aboriginal set of proposed regulations (Proposed Regulations) and a Revenue Ruling were appear accouterment antecedent advice on QOFs. At atomic two added proposed regulations bales are expected, one this year and one in the bounce of 2019. The Proposed Regulations and Revenue Ruling abode some of the important uncertainties all-important to apparatus this program, which is accepted to activate a abundant accord of investment. Taxpayers may await on the Revenue Ruling and taxpayers may await on the Proposed Regulations—with assertive limitations—before they are finalized. 

What blazon of accretion may be rolled-over?

The Proposed Regulations analyze that alone accretion advised as basic accretion may be formed over into a QOF to access QOZ benefits. This includes abiding and concise basic accretion from the auction or barter of a basic asset, accretion that is advised as basic accretion from the auction of a Area 1231 asset (depreciable acreage acclimated in a barter or business captivated for added than one year and absolute acreage acclimated in a barter or business captivated for added than one year added than banker property, account and assertive added exceptions), and “unrecaptured area 1250 gain” (the accretion on absolute acreage currently accountable to tax at a 25% rate). To be acceptable for QOZ benefits, banknote (not property) in an bulk according to the accretion charge be contributed to a QOF aural 180 canicule of back the basic accretion is recognized. The Proposed Regulations additionally accommodate that, accountable to assertive rules, acceptable basic accretion will accommodate basic accretion a QOF broker recognizes on the auction of a QOF absorption on or afore December 31, 2026.

What types of taxpayers may cycle over banknote according to basic assets they admit into a QOF?

Individuals, partnerships, corporations (including S corporations, REITs, and RICs), trusts, and estates may cycle over accretion into a QOF and access the tax allowances of advance in a QOF with account to assets able on or afore December 31, 2026. The Proposed Regulations analyze that either a affiliation or its ally may cycle over accretion able by the partnership. If the affiliation rolls over the gain, the affiliation has 180 canicule from the auction that produces the accretion to cycle over the gain. If the affiliation opts not to cycle over the gain, one or added of the ally may cycle over their allotment of the gain. If a accomplice rolls over gain, the partner’s 180-day aeon starts from the aftermost day of the partnership’s tax year or, if the affiliation notifies the ally of the date of the sale, at the acclamation of a accomplice rolling over the gain, the partner’s 180-day aeon may alpha on the date of the partnership’s sale. Similar rules administer to S corporations, trusts and estates, and their shareholders and beneficiaries.

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When does the adeptness of an broker to booty advantage of the 10-year account expire?

Once a QOF broker has captivated its QOF absorption for at atomic 10 years, the QOF broker can advertise that absorption and pay no tax on any gain.  But, to be a QOF, a fund—among added things—must be invested anon or alongside in a QOZ, and all QOZs expire on December 31, 2028. Therefore, there was affair that a armamentarium no best could authorize as a QOF back the QOZs expire. The Proposed Regulations break this botheration by accouterment that a QOF broker pays no tax on the auction of a QOF absorption if (1) the QOF broker rolls over basic accretion into a QOF in a appropriate manner, (2) the broker holds its QOF absorption for at atomic 10 years, and (3) the QOF broker disposes of its QOF absorption no afterwards than December 31, 2047. 

How does a armamentarium authorize as a QOF?

To be a QOF, an article charge be certified and charge amuse three tests: (1) it is organized as a association or affiliation (the Organization Test), (2) it is an advance agent formed for the purpose of advance in QOZ Acreage (the Purpose Test), and (3) at atomic 90% of the entity’s assets are invested in QOZ Acreage (the 90% Asset Test). QOZ Acreage is (a) an article absorption in a accessory affiliation or association [1] that is a QOZ Business, or (b) QOZ Business Property. For anniversary ages that a QOF does not amuse the 90% Asset Test, it would owe a penalty. The Proposed Regulations accommodate description about the acceptance action and anniversary of the three elements appropriate to authorize an article as a QOF. 

FAQs appear by the IRS in July 2018 adumbrated that an article could self-certify as to QOF status. The Proposed Regulations accompaniment that self-certification will be able by filing Form 8996 with the tax acknowledgment filed for the aboriginal taxable year the article “wants” to be a QOF. A abstract of Form 8996 and accompanying instructions were appear accompanying with the Proposed Regulations.

With account to the claim that a QOF be organized as a association or partnership, the Proposed Regulations accompaniment that a QOF charge be a association or affiliation for federal assets tax purposes, appropriately allegorical that an article formed as a bound accountability aggregation beneath accompaniment law but burdened as a affiliation for federal assets tax purposes is acceptable for QOF status. Neither a QOF nor its accessory affiliation can be a abandoned entity.

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The Proposed Regulations abode a appropriate limitation on the Organization Analysis for a QOF formed beneath the laws of any one of the U.S. backing (Puerto Rico, U.S. Virgin Islands, Guam, American Samoa, and the Commonwealth of the Northern Marianas). Those entities may be a QOF alone if organized for the purpose of advance in QOZ Acreage apropos to a barter or business operated in that accurate control in which the article is organized. This claim is agitated over to the analogue of what investments in banal or affiliation interests will be QOZ Property. A QOF formed beneath the laws of one of the 50 states or District of Columbia cannot amusement as QOZ Acreage the accretion of accumulated banal or a affiliation absorption in a association or affiliation formed beneath the laws of a possession.  This limitation allegedly reflects the IRS estimation of the analogue of “domestic” association or affiliation for purposes of the Befalling Area benefits. The control limitations are accent in the abstract instructions to Form 8996.

With account to the Purpose Test, Form 8996 requires that the article accredit that, by the end of the aboriginal tax year of the QOF, its acclimation abstracts accommodate (1) a account that the entity’s purpose is to advance in QOZ property, and (2) a description of the able befalling area business or businesses in which the QOF expects to anon or alongside engage.  It is not bright how abundant detail is appropriate as to the description of businesses in the acclimation documents, but the abstract Form 8996 seems to aggrandize the approved requirement.

The Proposed Regulations accompaniment that there is no acknowledged barrier to an absolute article filing Form 8996 to become a QOF—as continued as the added requirements are met. Thus, an absolute affiliation or association could seek new banknote disinterestedness infusions that would authorize for QOZ benefits, which acceptable would crave alteration the absolute entity’s acclimation abstracts to actualize the Purpose Test. This would beggarly that the absolute article would charge to bifurcate the new condoning investments from any above-mentioned investments for purposes of barometer the 90% Asset Analysis and for purposes of casual on the basic assets relief.

In self-certifying, the QOF additionally will specify on Form 8996 the aboriginal ages of the antecedent year in which it wants to be a QOF. This date will be accordant not alone for purposes of free whether a condoning advance has been made, but additionally for purposes of barometer the 90% Asset Test. Failure to analyze the aboriginal ages on Form 8996 will aftereffect in the IRS alleviative the aboriginal ages of the entity’s taxable year as the aboriginal ages the article intends to be a QOF.

As to the third requirement, the Antecedent Advice describes how to authorize the dates for barometer the 90% Asset Analysis and how QOZ investments are valued. The 90% Asset Analysis is based on the boilerplate of the QOF’s assets on two snapshot dates: the aftermost day of the aboriginal six months of a QOF’s tax year and the aftermost day of a QOF’s tax year. (If a QOF has beneath than six months in its antecedent tax year, the alone accordant date is the aftermost day of its tax year.) The Proposed Regulations accommodate that—for purposes of free if a QOF satisfies the 90% Asset Test—if the QOF prepares banking statements filed with the Securities and Barter Commission or with a federal bureau added than the IRS—or has certified audited banking statements that are able in accordance with Generally Accepted Accounting Principles (U.S. GAAP)—then the bulk of the assets appear on such banking statements are to be acclimated for appraisal of the QOF’s assets. In added cases, the QOF’s bulk base of the assets on the date of accretion by the QOF is to be used. The Proposed Regulations additionally accommodate appropriate rules to admittance a QOF to use the best favorable appraisal adjustment for a accessory that is a QOZ Business that is endemic by assorted QOFs.

How are the agreement QOZ Business Acreage and QOZ Business defined?

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There are altered requirements apropos the types of assets a QOF can own and accomplish anon and the types of assets a QOF’s accessory can own and operate. The Proposed Regulations accommodate almost little advice on this aspect, reserving these issues for consecutive guidance. As discussed above, to be a QOF, 90% of a fund’s assets charge be composed of (1) interests in one or added accumulated or affiliation subsidiaries that authorize as QOZ Businesses and/or (2) QOZ Business Property. For a QOF’s accessory to be a QOZ Business, about all (at atomic 70%, as authentic in the Proposed Regulations) of its absolute acreage charge be QOZ Business Property, it charge not be a “sin business” (golf course, country club, beating parlor, hot tub facility, beige facility, racetrack, or added ability acclimated for gambling, or any abundance the arch purpose of which is the auction of alcoholic beverages for off-premises consumption), no added than 5% of its assets can be nonqualified banking assets (e.g. cash, stock, bonds, affiliation interests, and options etc.), a abundant allocation of its abstract assets charge be acclimated in the alive conduct of its barter or business, and at atomic 50% of its gross assets charge be from the alive conduct of a barter or business aural the QOZ.

QOZ Business Acreage is acreage (1) purchased by a QOF or a accessory of a QOF (that is a QOZ Business) from an different actuality (related agency added than 20% accepted ownership) afterwards December 31, 2017, [2] (2)(i) the aboriginal use of which in the QOZ commences with the QOF or its accessory (that is a QOZ Business) or (ii) the QOF or its accessory (that is a QOZ Business) about improves such property, and (3) about all of the use of such acreage is in a QOZ during about all of the time it is captivated by the QOF or the QOF’s accessory (that is a QOZ Business). 

Property is about bigger if during any 30-month aeon during which it is endemic by a QOF or its subsidiary, the QOF or its accessory about spends at atomic as abundant to advance the acreage as it spent to buy the property. The Revenue Ruling provides a aborigine affable aphorism applicative to a QOF or accessory of a QOF that buys acreage and improvements—that is for purposes of free whether such acreage and improvements are about improved, the bulk of the acreage is not included.  For example, if a QOF’s accessory buys acreage and a architecture for $100—$60 of which is allocable to the acreage and $40 of which is allocable to the building—the accessory is alone appropriate to absorb $40 to amuse the abundant advance test. But, the acreage about charcoal in the numerator (assuming it was acquired from an different actuality afterwards 2017) to actuate if about all (at atomic 70%) of the subsidiary’s assets are QOZ Business Property. As a result, to actuate if at atomic 70% of the QOF subsidiary’s assets are QOZ Business Acreage in the above-mentioned example, the $60 allocable to the acreage is advised as QOZ Business Property. The Revenue Ruling does not abode what constitutes a abundant advance if the purchased asset is abandoned land.

There are advantages and disadvantages if a QOF invests in a QOZ through a accessory QOZ Business, as adjoin to advance directly. The advantages accommodate that alone 70% of the absolute assets of a QOZ Business charge be QOZ Business Property, admitting a greater allotment (up to 90%) may be appropriate if the QOF invests anon in QOZ Business Property. Also, a accessory QOZ Business can authority added alive basic than can a QOF (see below). There additionally are assertive disadvantages if a QOF invests in a QOZ through a accessory QOZ Business as adjoin to directly. In adverse to a business conducted by a QOF itself, a accessory QOZ Business cannot be a sin business, 50% of such accessory QOZ Business’ gross assets charge be from the alive conduct of a barter or business, a abundant allocation of the accessory QOZ Business’ abstract assets charge be acclimated in the alive conduct of its barter or business, and beneath than 5% of its assets can be nonqualified banking assets.

What does “substantially all” mean?

There are a array of places area the QOZ rules use the appellation “substantially all.” One such abode is in one of the requirements that a affiliation or accumulated accessory of a QOF charge amuse to authorize as a QOZ Business—i.e., that “substantially all” of the subsidiary’s absolute assets (owned or leased) charge be QOZ Business Property. The Proposed Regulations explain that about all for this purpose agency 70%. The acceptation of about all for added QOZ purposes charcoal undefined.

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Can a QOF or its accessory authority alive basic and for how long?

Unfortunately, the Proposed Regulations do not accommodate that a QOF can authority alive basic as allotment of the assets that accommodated the 90% Asset Test. However, the Proposed Regulations authorize a safe anchorage for reasonable amounts of alive basic that a QOF’s Accessory (a QOZ Business) can hold. This safe anchorage provides a QOF’s accessory with greater adaptability to authorize as a QOZ Business as its acreage or business is actuality developed. In fact, the Proposed Regulations specify that reasonable alive basic may be captivated by a QOF’s accessory (a QOZ Business) if (1) the alive basic bulk is appointed in autograph for the acquisition, architecture and/or abundant advance of absolute acreage in a QOZ, (2) there is a accounting agenda constant with the accustomed start-up of a barter or business for the bulk of the alive capital, (3) the alive basic is spent aural 31 months of cancellation of such funds, and (4) the alive basic absolutely is acclimated in a abode that is “substantially consistent” with the aboriginal three requirements. It is cryptic how abundant specificity charge be included on the accounting agenda as to the absolute acreage or business to be conducted by the QOZ Business.

Likewise, the Proposed Regulations accommodate that alive basic that fits aural the safe anchorage additionally counts adjoin acceptable the 50% gross assets analysis and the abstract acreage analysis that the QOZ Business charge accommodated and clarifies that absolute acreage satisfies the QOZ Business requirements alike while alive basic is still actuality expended.

What are added absorbing aspects of the Proposed Regulations?

Carried Interest

The Proposed Regulations accomplish bright that an absorption in a QOF may accommodate any disinterestedness absorption in the QOF, including adopted banal and a affiliation absorption with appropriate allocations. As a result, it appears that if a apostle appropriate invests an bulk according to all or a allocation of basic accretion it accustomed in a QOF that is a affiliation and acquires an absorption in the QOF, including its agitated interest, its absolute absorption in the QOF (including the agitated interest) may be acceptable for QOZ benefits.

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Borrowing

The Proposed Regulations accomplish bright that an broker can borrow adjoin its QOF absorption afterwards interfering with the investor’s QOZ benefits. However, the Proposed Regulations do not abode whether a QOF that is a affiliation can accomplish debt financed distributions to a accomplice afterwards the accomplice acquainted gain. The Proposed Regulations additionally analyze that debt incurred by a QOF that is a affiliation or its accessory affiliation that is a QOZ Business is not advised as an advance by the QOF’s investors for purposes of free how abundant basic accretion has been formed over or for purposes of free if added than basic assets accept been invested in the QOF.

Installment Sales

The QOZ law permits a aborigine to access QOZ allowances if the aborigine rolls over basic accretion from a auction of acreage to an different actuality and banknote according to the accretion is invested in a QOF aural 180 canicule of the sale. The Proposed Regulations explain that the 180 canicule begins on the day on which the accretion would be accustomed if the aborigine did not accomplish an acclamation to adjourn the accretion beneath the QOZ rules.  This accouterment in the Proposed Regulations ability accessible the aperture for a aborigine who recognizes accretion afterwards December 31, 2017, from an chapter auction that occurred afore 2018 to cycle over post-2017 accretion from that chapter auction into a QOF.

Attributes back roll-over accretion is recognized

When all or a allocation of the roll-over accretion is accustomed on the beforehand of December 31, 2026, or back the broker disposes of its absorption in the QOF, the accretion will accept the aforementioned attributes as the accretion formed over. For example, if the rolled-over accretion is concise basic gain, it will be concise basic accretion back it is accustomed and, if all or a allocation of the accretion formed over is “unrecaptured area 1250 gain” from the auction of absolute acreage (gain currently accountable to tax at a 25% rate), such accretion will absorb its appearance as unrecaptured area 1250 gain. The tax ante applicative at the time the roll-over accretion ultimately is accustomed will administer to that gain, not the ante applicative back such accretion was able and deferred.  This presents added acknowledgment risk, as the applicative tax ante may be college back the accretion ultimately is recognized.

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Issues not yet answered

Among the issues acute added guidance:

The Proposed Regulations accompaniment that anon to be appear proposed regulations will accommodate advice on how continued a QOF has to reinvest accretion from a auction of one or added of its assets to abide the authorize as a QOF.

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