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Abstract: 

In order to encourage economic growth and investment in distressed communities, as part of the Tax Cuts and Jobs Act of 2017, Congress enacted provisions that allow taxpayers to defer and exclude capital gain invested in “qualified opportunity funds,” located in “qualified opportunity zones.” This article explains the tax treatment of these investments and suggests ways that private foundations might leverage and amplify the benefits Congress sought to create.

Keywords: Qualified Opportunity Zone; Qualified Opportunity Fund; Exclusion of Post-Acquisition Gain; Non-Income Tax Reasons for Private Foundations to Invest in QO Funds

Affiliations:  1: Clark Hill Strasburger.