Qualified Opportunity Zones

Steptoe's multidisciplinary team helps clients effectively address the regulatory uncertainty associated with investing in qualified opportunity zones and appropriately structure investments in order to maximize the tax benefits. Bringing together substantive legal knowledge in tax, real estate, corporate, and securities law, coupled with extensive tax policy and public policy experience, we provide clients with a comprehensive understanding of the regulatory nuances of opportunity zones. In particular, clients benefit from our deep technical understanding of the tax regulations that govern the structure of the opportunity funds and are critical to whether clients are able to realize the potential tax benefits associated with investing in an opportunity zone.

Our team has been involved in qualified opportunity zones from the outset, from our work on the original bill that made its way into the Tax Cuts and Jobs Act, in which this new tax incentive was enacted, to working with and advising a leading coalition during the rulemaking process, to advising investors on structuring potential investments and investment fund vehicles. We advise investors, fund managers, real estate owners, and businesses looking to operate in opportunity zones in matters involving qualified opportunity zones and opportunity funds.

Among the designated opportunity zones, Puerto Rico presents one of the greatest areas of opportunity, with 98% of the island designated an opportunity zone. Steptoe has a long history working on and with the island in a variety of matters. As a result, we are well situated to help companies and individuals contemplating opportunity zone investments in Puerto Rico as well as any other part of the country designated as an opportunity zone.

We can assist in:

• Planning and structuring qualified opportunity funds and qualified opportunity zone businesses for investing in opportunity zones, including drafting the organizational and transactional documents
• Advising investors and investment funds on the tax rules governing investments in opportunity zones
• Representing companies on acquiring real estate and other business assets in opportunity zones
• Advocating for changes to the regulations, including preparing comment letters and meeting with policymakers