Qualified Opportunity Fund Structuring For PE Sponsors

By Robert Holo and Tyler Robbins (February 14, 2019, 5:53 PM EST) -- Tax professionals are, for better or worse, the most popular guests at cocktail parties in 2019. Everyone wants to talk about qualified opportunity funds, or QOFs. Much has been written about QOFs, from the confusion surrounding the technical requirements to the generous tax benefits, and everything in between. However, high-level attention to QOF structuring for private equity sponsors seems to be lacking. In this column we highlight several salient structuring points that are unique to QOFs, which sponsors and their advisers should keep in mind when thinking about putting together funds intended to take advantage of the QOF regime. ...

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