March 05, 2019 - 8:00 AM - 10:00 AM ET

A Complimentary Venable LLP Seminar

Opportunity Zone Funds: A Tax Incentive for Investments in Low-Income Communities

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Venable LLP
Rockefeller center
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24th Floor
New York, NY 10020

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Please join members of Venable and Morgan Stanley for a panel discussion on Opportunity Zone Funds. Created by the Tax Cut and Jobs Act of 2017, Opportunity Zone Funds are one of the newest tax-subsidized financing programs. Since its adoption, Venable attorneys have been advising clients on the parameters of this developing program. The speakers from Morgan Stanley will provide valuable insight on the investments from a business and finance perspective. Our seminar is intended for (i) investors looking to take advantage of the tax savings presented by investing in opportunity zone funds, (ii) sponsors looking to start opportunity zone funds, and (iii) real estate firms looking to develop assets in opportunity zones in compliance with this new federal program. The discussion will focus on:

  • Opportunity Zone Program Overview
    • Who – Tax Benefits for Investors & Eligibility Requirements for Investors
    • When – Timing Rules for Rolling Gain into an Opportunity Zone Fund
    • Where – Low-Income Communities
    • What – A Qualified Opportunity Fund & Eligible Projects
    • How – Forming a Qualified Opportunity Fund
  • Qualified Opportunity Zone Fund Structure
    • What Is a Qualified Opportunity Zone Business Property?
    • What Is a Qualified Opportunity Zone Business?
    • Single-Tier or Double-Tier Structure?
  • Real Estate Project Considerations
    • Participation by Current Owner – Avoiding Related Party Status
    • Partnerships – Use of Leverage
    • Comparison with Section 1031 Rollovers
  • Securities Laws Considerations
  • Business and Financial Considerations


Suzanne St. Pierre, Partner, Venable LLP


Erin Berry, Executive Director, Alternative Investment Product Origination & Development, Morgan Stanley
Michael Bloom, Counsel, Venable LLP
Walter Calvert, Partner, Venable LLP
Mihir J. Patel, Managing Director, Private Wealth Advisor, Morgan Stanley
Elizabeth Stieff, Associate, Venable LLP