BarbriSFCourseDetails

Course Details

This CLE course will provide energy counsel with an understanding of Qualified Opportunity Zones (QOZs) and Qualified Opportunity Funds (QOFs) created under current law. The panel will discuss eligibility requirements, formation, and self-certification, as well as the tax benefits associated with investing in QOZs. The panel will also examine how QOFs can be used in energy projects and the interplay with other tax incentives.

Faculty

Description

Tax reform created one of the country's most significant economic development programs that encourages private investment in Qualified Opportunity Zones. Qualified Opportunity Funds offer favorable treatment of returns on the investment, including deferral, reduction, or possible elimination of gains tax on the appreciation of the fund interest.

Individual states designated communities as QOZa, which have been approved by the Treasury Department and the Internal Revenue Service. Certain energy projects, including renewables, mineral extraction, and oil and gas, are particularly well suited for QOFs.

To leverage the tax benefits of the program, a taxpayer must reinvest gain proceeds in a QOF within 180 days from the date of the sale or exchange of a capital asset. A QOF must hold at least 90 percent of the fund's holdings in QOZ property.

Counsel to companies and others in the energy industry must understand the structuring requirements to qualify for--and preserve--these tax benefits through the life of an investment and the interplay with other tax incentives available for energy projects.

Listen as our authoritative panel of energy and tax professionals examines QOZs and QOFs. The panel will discuss tax benefits associated with making energy and other business investments in QOZs, eligibility requirements, the process for getting fund approval, fund formation, and more.

Outline

  1. Qualified Opportunity Zones: defined
  2. Qualified Opportunity Funds: eligibility requirements, formation, self-certification
  3. Tax incentives to invest in Qualified Opportunity Funds/Zones
  4. Interplay of Qualified Opportunity Zone investments with renewable energy tax incentive programs
  5. Structuring considerations

Benefits

The panel will review these and other critical issues:

  • What are QOZs, and how are they determined?
  • How are QOFs approved, and what is the preferred entity structure?
  • When must the reinvestment of gains be made, and how long must it be held to qualify for the tax benefits?
  • How might QOFs be used in energy projects, and can they be used with other tax incentives?
  • What is the status of Treasury regulations interpreting and clarifying essential aspects of the QOZ program?