Opportunity Zone Magazine Opportunity Zone Magazine Volume 1, Issue 1 | Page 77

DISSECTING OPPORTUNITY ZONE FUND STRUCTURES
been receiving comments since its release. In the hearing,
the IRS listened to witnesses in attendance who provided
comments and suggestions on a variety of topics including
how interim gains in connection with the sale of underlying
QOF assets will be treated, how e-commerce business can
qualify, clarification on how unimproved land is treated,
clarification on the original use test, clarification for how
operating businesses can qualify, and requesting that long-
term ground leases be treated as Qualified Opportunity Zone
Business Property. The next step is for the IRS to release the
second round of proposed regulations based on the comments
it has received.
Despite t he ma ny persisting u ncer tainties, t he first
round of regulations provided enough clarity that many
opportunity funds have been formed and are beginning
to make investments into projects. The market for the
program is on an encouraging uptrend as more and more
interested parties begin to learn about the program and
its exciting opportunities.
V ikram A garwal is a shareholder with Virginia-based Bean,
Kinney & Korman, representing a broad range of clients in tax
and corporate matters, particularly for the real estate, renewable
energy, government contracting and technology industries.
Agarwal has been at the forefront of the Qualified Opportunity
Fund program and has written and presented extensively on the
topic. Vikram is also personally involved as a principal in Qualified
Opportunity Funds in real estate developments. This gives him
the perspective of a developer and investor, which allows him to
understand needs in a way that most attorneys cannot.
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