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QOF (Qualified Opportunity Fund)

En español: QOF (Qualified Opportunity Fund)

Definition

A qualified opportunity fund is the corporation or partnership through which money has to travel to reach an Opportunity Zone. An investor cannot buy a building in a zone directly and claim the treatment. The fund elects its own status by filing, and it has to keep at least 90 percent of its assets in qualifying zone property, tested twice a year, for as long as it exists.

How to read it
How to read it
  • The fund is the taxpayer's structure, not the seller's concern. A seller is selling a building either way.
  • Self-certification is not approval. Filing the election starts the obligations; nobody at the IRS confirms the fund is doing it correctly.
  • The 90 percent test runs for the whole life of the fund, not just at the start. Year seven is a testing year the same as year one.
  • Fund documents are a securities and tax question. The building is the part a broker can read.
An example
An example

A fund's assets on a semiannual testing date.

Building and improvements in the zone$1,700,000
Cash held for the next draw$300,000
Share in qualifying property85%
Passes the 90 percent testNo

Idle cash is the ordinary way a fund fails a test it was never at risk of failing on the real estate. The working capital rules exist for exactly this, and they have to be set up in writing beforehand.

Note

Tax mechanics change and individual situations differ. Treat this as orientation, not tax advice; the numbers on a specific transaction belong with a CPA or qualified intermediary.

Terms arrive with the writing.

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