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About the Course
Introduction
This CLE/CPE course will provide estate planners and advisers guidance on key challenges and planning considerations when incorporating qualified opportunity zone fund (QOZ) investments in estate planning after the One Big Beautiful Bill Act (OBBBA). The panel will discuss the current regulatory and tax framework around QOZs, including recent changes and developments ushered in under OBBBA, and explore effective transaction structures and estate planning techniques to manage both tax and non-tax issues, taking into account the highly nuanced tax rules that apply to QOZ fund investments.
Description
If properly structured, investors in QOZ funds have tremendous estate planning opportunities for their interests under current tax law. Estate planners and advisers must understand applicable tax rules in order to assist clients in deferring capital gains, increasing basis in long-term investments, and utilizing available estate planning methods to avoid any adverse tax implications.
This program will address the rules that trusts and estates counsel, and other estate planning and financial advisers, need to know in implementing a plan that involves investments in QOZ funds after OBBBA, which permanently extends the QOZ program scheduled to sunset on Dec. 31, 2026. Special attention will be paid to the practical application of these rules, including state-specific decoupling considerations, and what estate and financial planners need to know about these specialized rules. The panel will also address how investments in QOZ funds may fit within the panoply of estate planning techniques that are commonly employed to facilitate the transfer of wealth, such as GRATs and installment sales to grantor trusts, and carried interest planning considerations when representing the fund manager that is sponsoring the QOZ fund.
Listen as our experienced panel discusses estate planning challenges for QOZ fund investments. The panel will discuss planning techniques that take advantage of wealth transfer opportunities while avoiding unintended adverse tax consequences.
Presented By
Mr. Matz, Partner at ArentFox Schiff focuses on domestic and international estate and tax planning, estate administration, and related litigation. He counsels clients on wealth transfer planning; drafting wills and trusts; gift, estate, income, and generation-skipping transfer tax planning and tax return preparation; charitable gift planning; probate proceedings and estate administration; and associated litigation as well as corporate counseling. Mr. Matz has advised clients on entity and succession planning, including use of family limited partnerships, use of grantor retained annuity trusts, transfers to irrevocable trusts involving complex valuations, qualified personal residence trusts, irrevocable life insurance trusts, and the use of charitable remainder trusts, charitable lead trusts, and private foundations to further family planning and philanthropic objectives. He also counsels clients on family office structuring, and co-chairs ArentFox Schiff’s Family Office Industry Group.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
Date + Time
- event
Thursday, July 30, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. OBBBA rules
II. Applicable income, estate, and gift tax rules and issues, including income in respect of a decedent upon death (IRD)
III. Use of grantor trusts and other applicable estate planning techniques, including GRATs, and planning for no step-up in basis upon death due to IRD
IV. Valuation issues and special rules
V. Best practices and other challenges for estate planners
The panel will review these and other key issues:
- What is the impact of OBBBA on estate planning for QOZ interests?
- What are the income, estate, and gift tax ramifications of investing in QOZ funds?
- What are the available planning techniques for QOZ fund investors and fund managers, and what are the unique pitfalls to watch out for?
- How can GRATs and defective grantor trusts, among other estate planning techniques, be utilized to minimize taxes, and what are the challenges in the QOZ context?
- What is the impact of the deferred gain recognition date of December 31, 2026 under "Tranche 1" of the QOZ rules?
- What are the valuation issues and their impact on overall planning, including under the final QOZ regulations with respect to the upcoming deferred gain recognition date of December 31, 2026?
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