Established by the Tax Cuts and Jobs Act of 2017, the Federal Qualified Opportunity Zone Program is designed to promote and drive long-term investment in designated low-income areas by allowing taxpayers to defer, and potentially reduce, the recognition of capital gain if the capital gain proceeds are invested in a Qualified Opportunity Fund. Further, if the taxpayer holds the investment in the Qualified Opportunity Fund for at least 10 years, the entire gain on all appreciation of the Qualified Opportunity Fund during the investment period will be excluded from taxation.

In response to this innovative program, CSG Law has developed a multidisciplinary Qualified Opportunity Zones Team consisting of attorneys representing the firm’s Real Estate, Development & Land Use; Tax; Corporate & Securities; Environmental; Public Finance; and Trusts & Estates Groups.

Our firsthand experience helping clients maximize their participation in similar economic revitalization initiatives – such as New Jersey’s 2008 Urban Transit Hub Tax Credit Program, and the federal New Markets Tax Credit and Low-Income Housing Tax Credit programs – coupled with the firm’s deep real estate, transactional and tax practices, places CSG Law in a unique position to support stakeholders as they implement the Qualified Opportunity Zone Program into their business and tax minimization strategies.

The Qualified Opportunity Zones Team advises investors, developers, fund managers, property owners and business owners with regard to the legal and regulatory requirements needed to successfully participate in, and comply with, the federal Qualified Opportunity Zone Program.

Our attorneys provide insight on matters pertaining to:

  • Investment in Qualified Opportunity Funds
  • Design and formation of Qualified Opportunity Funds
  • Deployment of capital by Qualified Opportunity Funds
  • Tax and regulatory compliance
  • Structuring business operations to maximize potential for investment from Qualified Opportunity Funds
  • Real estate acquisition, redevelopment and zoning
  • Public incentive programs, tax credits and payment in lieu of taxes (PILOTs)
  • Environmental due diligence
  • Wealth and transfer tax planning


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April 2021