Ronald Fieldstone
The Opportunity Zone Expo Podcast
A 40 Year Record of Capitalizing on Opportunuties
Transcription
Jack: Well, welcome back. Everybody to the OZExpo Podcast. I'm your host, Jack Heald. And joining me for this episode is Ronald Fieldstone of the law firm Saul Ewing Arnstein & Lehr. Ronnie, welcome to the OZExpo Podcast.
Ronnie: Thank you. Good to be here.
Jack: Good to have ya. So, I try to find out a little bit about my guests before we go into the expertise that you bring to the field. Tell us a little bit about yourself. Where'd you come from? How'd you get here? That kind of thing.
Ronnie: Yeah. Well I was born, I grew up in Toronto, Canada. So, I'm actually a foreigner and not too far away. And I migrated to United States in high school and then as an F1 student went to University of Pennsylvania at the Wharton school and then continued to get my master's degree and my MBA degree at Wharton and my law degree at Penn Law. At which time I actually became a green card resident because I married an American. So that got me my green card. I'm still married by the way. So that worked very well.
Jack: Congratulations.
Ronnie: Thank you. And then when I graduated and I moved to Florida, to start my law practice. I'm in Florida, permanent resident of Florida ever since and seen the tremendous transition of the south Florida area from a kind of a sleepy town to a world class city.
Jack: So, you went through the downturn of 2008. Describe that a little bit both from a professional and a personal experience standpoint?
Ronnie: Well, it was obviously devastating to the economy because the Miami area got hit as bad as what not, it'll because it was such a boom and there was so much overbuilding and zealousness with financing and obviously the way it was very difficult on the economy and there was a total collapse in the real estate market and resulted in a very high unemployment, one of the highest foreclosure rates in the country. Where they actually, they got a foreclosure. Foreclosures were taking two years to get done, it was a very difficult time. And the good news was Miami and south Florida are such resilient economies that they were able to rebound when things started getting better and it all came back starting 2011, 2012.
So, there was a probably about a three-year very bad period. Then it started going upwards and believe it or not, values came back to their norms prior to 2008 and even exceeded those. And we've seen a total regeneration of the local economy to a booming economy. But this time around, much more conservative, much tighter controls on financing. And we're not seeing any real estate collapse whatsoever in the local economy today, and it's still thriving, especially given the fact of the problems and other countries and Miami being a, a haven for residents and citizens coming from many countries, in particular, Latin America, also Europe, Russia, other areas.
So I live in a wonderful dynamic environment, which by the way, recently, there was an article in… Concerning, since we're talking about Opportunity Zones, the a Wall Street Journal had an article in the Wednesday edition entitled "Low Income Tax Breaks Fuel Luxury Developers in Miami". And it talks about Miami being the most prolific city to take advantage of Opportunity Zones, first quarter's sales of development sites in Miami Opportunity Zones grew 45%. So what we're seeing is a very dynamic economy; a very fast growing inner city that was underdeveloped and Opportunity Zone designations so they're extremely viable for development. Which makes Miami one of the really very desirable cities for the OZ program. And given the sophistication and the tremendous access to capital in this market, there's a tremendous amount of activity in these projects going on right now
Jack: Prior to the show you and I we're talking about some of the criticisms of the Opportunity Zone program. We've got a pretty educated and sophisticated audience here, so we don't have to go to the elementary, you know, Opportunity Zones 101. Why don't we dive into that discussion we were having earlier when you were telling me about your daughter and. …
Ronnie: Yeah. Sure. So, so I did, I wrote my first article Opportunity Zones sometime in December of last year. And I gave, I gave a copy to my daughter because it was talking briefly about what a terrific program it was. The benefits for developers and tax incentives and how viable it was, which is true. And my daughter, being an educator, a Harvard-educated educator that teaches teachers at an underprivileged school in the Boston area, she wrote me back saying, “Great program, Dad, but what are you doing for the people in the area? What are they getting out of this program?” And I thought about it and I said, “You know, you're right, I'm gonna, I'm gonna make this a cause celeb and I'm going to research it.”
So, I went and researched every article I could find on Opportunity Zones from a social policy standpoint, and I wrote an article called "Opportunity Zones: Who's opportunity is it really?" And I broke out the analysis done by many publications. Primarily example being the economist in November wrote a very scathing article on Opportunity Zones. And the bottom line was that the legislation and at that time, the first set of regulations that came out in October had absolutely no accountability for the effect on communities and the citizens and residents of the people will live in an Opportunity Zones. Zero.
Unlike other countries or other types of programs like the Empowerment Zone program, which is a successor to that really had some track-ability of what was going on with these programs. Given the fact that federal government's giving tax incentives to encourage people, to put money in Opportunity Zones because of, the theory would be, but for these tax incentives, development may not have taken place.
Well, the reality is the criticism of the program, multiple sentence, No.1, no accountability to no traceability. Three a lot of zones that were designated may have been developed anyways without the benefit of the OZ regulate, regulate legislation and regulations. And they call those re-gentrified areas because when they did the original analysis of eligible Opportunity Zones, they used the old census track information and therefore it was kind of stale. So you have areas that are extremely viable for development that are OZ areas. One questions: “Was that really the intent of the statute originally to enable areas that are being re-gentrified to become OZ areas? That's past news now because the law is the law. The designations are fixed for the time of the 10 year time period, so that's not going to change and therefore we are dealing with what we have and if you look at some of the major metropolitan areas in the country, some areas have particular New York, Manhattan area where you have significant OZ designations in Brooklyn, Long Island City and areas that one would say are terrific areas for development.
They were being developed anyways. A matter of fact, the extreme was the Long Island City, which as we know was going to be a secondary headquarters for Amazon and they changed their position for various reasons, but got substantial criticism from the New York Times when that happens that they even now going to take advantage of the OZ. And that was not intended to benefit Amazon because Amazon was in and now he's out. I'm not suggesting a, they picked long island city because it was an OZ zone, but they got the indirect benefits.
Of course, that's a moot issue now because they elected not to proceed with their headquarters there. But that was a good example. So with another offshoot of this is recognizing the deficiency and the reporting requirements when the new regulations were issued on April 17th this year, the Treasury Department also issued a document called request for information on data collection and tracking for qualified Opportunity Zones.
And in summary, what they're saying is that the government wants, is seeking public input on the development. And I quote public information collection and tracking related to investment in qualified Opportunity Zones. And I continue, they talked about the acts seeking to encourage economic growth and investment in designated distressed areas.
They call it designated distress here by providing tax benefits to taxpayers who invest. The purpose of the information is to track the measure of the effectiveness of the policy and achieving stated goals, while making the investment viable. So the stated of goals was to re-gentrify or regenerate impoverished areas to become more desirable for everybody. But the law itself had no tracking mechanism to determine what effect it had on the community. So this proposal which is being proposed will be required that OZ funds will need to provide data reporting when this becomes published.
Because right now it's a proposal to track items that they, the government and based upon responses received from the audience deem appropriate. For instance, they suggest, I'll give you an example, measure that would signal improved economic development in local target markets and spill over areas. Measures of job creation in distressed communities. You know and things of that nature. So in my analysis of articles, I have focused on a few key factors, or it should be at least factored into the government program big time and at least understanding what's happening. Obviously job creations, number one, OZ projects have to spend money, so by definition they're going to create jobs. The question is how many jobs and where are the jobs going to? Are they going to people outside the OZ zones? Are they going to people inside the OZ zone? Affordable housing. We know that residents are going to be displaced because there's going to be housing.
It's going to be torn down because it's antiquated. I'm not complaining about that, but what's happening to the people in the area? Is subsidized housing going to be made available to these people so that they don't have to leave the area? Increase in services because the lower income population, needs transportation health care or healthy food options, education? Engaging local residents in the process, there's no system now that the local residents have any say what's going to happen. And then the biggest thing is big things are taking advantage of community redevelopment agency grants. Many areas including south Florida, municipalities have a CRA, community redevelopment agencies that provide grants to people that develop businesses or projects in distressed areas. And what role is the municipal and state is going to take in this initiative and the assistants and monitoring clearly that there was no monitoring mechanism to factor this in.
So, I think the government initiative now, the Treasury Department is trying to collect data and that doesn't mean it's required. I want to make that clear. Just because they collect the data. It doesn't mean you as a developer or a sponsor need to necessarily provide jobs, services or the like it, but at least to track the information. Now why are they tracking information? So down the road they determine the success of the program, not just economically to taxpayers who would take advantage of the program, but the communities that was supposed to be the beneficiary of the program. In addition, I think it's going to encourage, and it has encouraged local governments to take an initiative that's very valuable. So, as we speak today, I'm aware of 16 states and the island of Puerto Rico, which obviously is U.S. Territory. They're proposing legislation that if you meet certain requirements, the state will give you benefits in addition to the federal benefits.
That could be grants, it could be sales tax reductions, property tax reductions or other grant subsidy grants if you develop certain products. A lot relates to housing, energy services, jobs, trading. And other things that communities, think are valuable to their residents. So what they're now doing this saying you could, you can get the federal benefits with or without us that we as a municipality or as a state will give you other benefits, if you play ball with us and do something that is beneficial to the community and so that's accountable or you get the ben... That tax, we'll give you extra tax benefits to supplement the federal tax benefits. And I think that's going to be very valuable. And I think that's going to play itself out.
Jack: As a tax attorney, you have clients coming to you. How are you advising them to set up their funds, I'm assuming it’s primarily funds to manage this not-yet-required tracking, or are you?
Ronnie: Well that's two questions. First of all, you have to set up the first, I mean let's understand and I want to make this very clear, the OZ program does not make a bad project good. Because if you don't make any money, you don't get the benefits of the capital gains appreciation tax free. So let's understand one thing, right? You know that the industry is telling everybody, projects have to work no matter what. Projects are not bad, project should not get done.
Ronnie: So the project itself has to make economic sense because if you don't make money what difference does it make?
Jack: Yeah.
Ronnie: You're not getting the capital gains benefits. So I think number one, the first advice to everybody is make sure you have a viable project. The second advice is make sure you structure it right from a tax point of view to get the major tax, OZ tax benefits awarded. The next thing we're advising our clients is to look at all the municipal state benefits that are being offered, independent of the OZ program. That would be a creative to the project, but at the same time, a local benefit is going to be tied to services and benefits for the local community.
So, what I'm seeing, which I like a lot, is the communities are starting to take an active role. Virtually everybody in the country is woken up and understands Opportunity Zones are here and it's relevant. And that's going to be a major player, not just in real estate but a major player in setting up new businesses that could grow in an Opportunity Zone and get tremendous benefits going forward. For example, a lot of your incubator companies, tech companies that aren't retail oriented could just as easily located in the OZ zone is located in a non-OZ zone. If they locate in OZ zone, like if another Google or Facebook or you know, some of these companies come around and they located in those OZ zone and they become very successful, go public.
That Bennett that qualifies under the OZ Program. Could you imagine what a tremendous benefit that is?
Jack: Oh Lord.
Ronnie: Having a startup that becomes very valuable, and so we're seeing people analyze carefully, purposely locating OZ projects or businesses and in OZ zones that don't have to be there, but they realize the potential of growing a business into a mega-business and getting the capital gains appreciation tax free is very valuable. Plus of course the location costs in an OZ zone are going to be less expensive. By definition, you're going into a zone that's not primary and it creates jobs and services and it's good. So I think that's where we're going to see a play.
Obviously, we're going to see real estate plays in re-gentrified areas, big time where you're in a zone where you're next to major development. Like they focused on the Wall Street Journal article I mentioned earlier. They show the high rises in the OZ zone and they're developing new OZ projects right next to it. And you'll say to yourself, how could this be an OZ zone? Look what's going up there. But that's, that's what's going on. That's why the market in particular in downtown Miami is so vibrant because it's generated so much extra traffic because of the tax incentives in areas that were already very valuable for development. But again, and then the other item is by going to the governments, you're going to have to track what you're doing. You're going to have to track it because the government is going to make you.
And the other item is there's a kind of an investor base. I call them, maybe you can call them green investors or people that invest based upon societal benefits. And there are certain funds I'm aware of that actually have set aside money. Then we'll only invest in projects that help the local community. They're not gonna, they just don't want to invest in projects to make money. They want some of their money going into areas that may otherwise not get it because they may want, they may even take a lower return if they can feel it. They believe that this was going to create a community benefit. So that I think there's going to be some societal pressure among wealthy investors. Cause this was mainly going to be wealthy investors who are going to be putting their money in those projects to look at the social benefits.
So, I do believe that if I'm a d, if I'm representing the developer in planning, that I surely would emphasize the social benefits of the program. For instance, when I was at a conference recently and the mayor of Miami, Mayor Suarez showed up. He is a big proponent of Opportunity Zones and he said, which was really valuable. The City of Miami will do anything possible to expedite your processing of all your permits and plans to help you develop your project, you know, with as least red tape as possible. So he made a public statement that he is supporting us and I think you're going to see that across the board, the government officials are going to buy into this. And providing, they like what you're doing and they feel it's benefiting the government or the society, they're going to be very proactive.
So, one, look to government. Many times you'll look at government as being a burden, which it is to some degree and stop in blocking or slowing down the process. OZ developments' governments may be very encouraging and supportive and expedite the process because they recognize it's valuable and the more they can do, they get valuable development that's done the right way, the better it's going to benefit the community. There's one thing that benefits the community, no matter what that I neglected to say. No matter what you do from a social benefit standpoint, you're going to increase the tax base. That's a given the property tax base.
Jack: Right.
Ronnie: And when you increase the property tax base, what do you do? You create more money. Okay. And that money goes to the local government authorities, the government authorities can elect to take that money and put it back and they have the right to do that.
So, to some degree the increase in value, which increases property taxes could go to special programs. That will again try to benefit those people displaced or enable those people displaced to stay in the area and possibly better their lives by getting them jobs, job training, etc. So I know, in some areas, like where I live there's job training incentives those where you train people and you get subsidies from the government, to train people to perform services and the local community if you live in, if the residents live in the area. So I think we're going to see a convergence of all know things. So as an advisor to a sponsor or developer, all of the things should be taken into account.
Jack: Are you familiar with anybody who is making impact tracking part of their, their basic approach to OZ investment yet?
Ronnie: No. Would I say no? I mean, I think it's too new. The government itself is even saying to the public. Please give us a list of the things you think we should track so we can monitor it. So, the government's gonna make you do it because I think that the Treasury Department in the near future is going to issue a guideline. There are guidelines and what they're going to require and if they, if they put it into a system, it's going to be required. And that of course, questions commentators make is that, “Well, how do you enforce it?” Because there there's no penalties.
Jack: Yes.
Ronnie: And they're going to have to pass legislation to enforce it. There's definitely going to have to pass legislation to enforce a type of different issue. But at least they took the road to lead based upon the, I think a lot of the comments from the public and government officials are trying to monitor what it's doing, so again, I think you're going to see a whole combination as part of the process and we're new in the game. People are still trying to understand OZ people are still trying to get their hands around how to do it. The regulations that a lot of people were waiting for just came out a little over two weeks ago, so we're still kind of new in the game as far as figuring out how to do this. There's a lot of people who are on the sidelines until the regulations came out.
Jack: Okay. I talked to a lot of folks in this business as you might imagine, and I'd say easily half of them mentioned the impact that OZ investing is supposed to have. They care about it; it matters to them that it actually has an impact in the zone and positive impact in the zone and not merely return a profit. My guess is the, the tax advantages are not sufficient by themselves to just draw anybody who's trying to make money by definition almost because it's in lower served communities. It's drawing people who are more interested in that kind of thing.
Ronnie: Well let me correct you there. Yes. Ideally what you said is correct. Ideally, but not when you're dealing with re-gentrified zones that are already being developed.
Jack: Ah okay.
Ronnie: And they didn't necessarily need the incentive.
Jack: Very good point.
Ronnie: There's just looking at the deals and saying okay I'm doing this deal anyways. Now I'm really doing the deal because…
Jack: Right.
Ronnie: I can now raise capital cheaper, or more readily because my investors can now get all these benefits that they wouldn't have got on a regular real estate deal or a business deal. So to some degree they're doing it either way. They just got a win. I hate to use the word windfall now. It does encourage more development, maybe more extensive development more timely development. So there is a benefit that I don't want to negate the timely cause your cause you have time to invest the money. The government's put a time clock…
Jack: Yeah.
Ronnie: And its benefits to accelerate the process. So I do believe in the normal courses, the development going on in those, these would have taken much longer. Now it's going to be accelerated because of the laws that are encouraging people to invest our money this year, next year, you know, within a short period of time to get the maximum benefits under the tax law.
I think it's a combination, but it's not like, oh, these deals wouldn't work without OZ benefits. There's many deals that would have worked without OZ benefits.
Jack: Well I think you were, it's obvious talking with your expertise is both deep and broad. As I've looked at your biography, you've got an awful lot of experience outside the realm of tax law as well. Lots of different franchises, Barneys, Blockbuster. Talk a little bit about those. How'd you get into those things?
Ronnie: Well, first I grew up in a business. I have an immigrant business family, so you'll learn when you're younger, when you have an immigrant father who started in the business. It's very telling. And then, um, I was fortunate enough in my law practice to get exposed to, you know, some greater business opportunities that I took advantage of. One being becoming a blockbuster video franchisee for 25 stores long before, um, the technology took over and being involved in a branded coffee chain and then getting involved in real estate of funds for multifamily real estate.
So all of those activities have, it just enabled me to, I think get a better grasp of all the moving parts in a business oriented tax law like OZ that's got tax issues but as a major, major business issues that need to be navigated at the same time. So I enjoy the fact that this was a new activity that's very interesting. Involves, yeah, many facets about business and law. Not just tax, but the real estate, corporate environmental government and then business operations and business opportunities. So it's really, uh, a really broad-based program that has no dollar limit and it's on its base and has a tremendous potential. So I think my, my background has been very helpful.
Jack: Oh, I would think so.
Ronnie: Giving me, you know, the, the ability to just appreciate and try to take advantage of what's available.
Jack: If you don't mind. Let's talk about the cannabis industry and its intersection with Opportunity Zones. I see that Saul Ewing Arnstein & Lehr is involved in the cannabis law area as well. What are your thoughts in that regard?
Ronnie: Yeah, well it's very good. First you have cannabis and then CBD, which is hemp. So the distinguishing factor in CBD hemp is, it is not deemed a drug. It doesn't have any federal restriction. As we know cannabis technically it's, the industry itself is against federal law, but it's not being enforced. And you have, I think 30 states now that have a cannabis law either for medicinal or recreational purposes. So the issue became very interesting when the first regs came out, when the law came out, and then the regs, a law came out? They have what's called sin activities.
Jack: Mmm, Right.
Ronnie: And there's certain activities excluded items like a massage parlors and liquor stores and golf courses and things that they're, not that they're bad moral judging that, but they said we're not, we're not going to let you benefits of the program to do these, what we call sin activities. And they listed them. It was about six or seven.
Jack: Right.
Ronnie: They did not put cannabis in there. They could have and they didn't. Yeah. One would argue, well it's illegal federally anyways, they didn't have to put it in. One would also argue, wait a minute, they could have put it in because there was restrictions on alcohol. There's restrictions on this. So the alcohol’s highly regulated and there's limitations on that. So, they could have put it in if wanted to.
And the answer was they didn't put it in. So one could argue the, and the people who are concerned with a federal, the IRS respect a cannabis business. It's in an OZ zone because it's not legal under federal law, but there are also federal laws, tax laws that excluded cannabis businesses from certain benefits. You can't take a loss, you can't get certain credits. So why would the IRS have special tax laws for the cannabis industry?
Which means you report your income and you pay tax on it. Even though technically it's violating federal law. Well at the same time excluded from OZ world. So we believe there is no reason that this time to believe cannabis will be excluded. If they wanted to exclude it, they would have excluded it. Now maybe there'll be future legislation that will exclude it.
Jack: Right.
Ronnie: So right now, it's not excluded, and we believe since it's not excluded, it should be viable. Now, don't forget, you have two types of cannabis. You have medicinal, which is a lot of the states, and you have recreational, which is a much smaller number of states. One could easily argue that from a medicinal purpose. It's got a great benefit to society. In my state, Florida. It after the second round, did past by a large margin as a medicinal use.
Ronnie: And most people do it, the substantial majority of the population and forward a view it as a benefit to society for all the right reasons.
Jack: Right.
Ronnie: So why would you then prejudice that type of business from any other business. Growing? You can grow, you know, um, agriculture people are talking about special hydroponics, power plants, energy as solar, you know, all things that benefit society. You know, I'm not making a moral judgment of cannabis should not be in that, that would not apply to CBD at all CBD would not be, and it should be because CBD is not a drug. And as you may or may not know, but CVS and Walgreens just announced they're putting CBD in a you know, substantial number of their stores. So nobody's questioning CBD at all. Cannabis, different story. So we believe it should be. Right now our people are telling us they're not looking at cannabis any different than because of OZ. As a matter of fact, it's opportunistic for OZ.
Jack: Seems like.
Ronnie: Because cannabis farms in areas that are OZ designated.
Jack: I was going to say; it seems like a natural fit for some of the rural areas. As far as I understand it, marijuana is a relatively difficult plant to grow, but people who know how to do it might be able to make it work.
Ronnie: They seem to be growing it all over the countries, states in the rowing it
Jack: I can kill anything green. So, you know, everything's hard for me.
Ronnie: No, but you're, you're well stated. But the rural areas, not just cannabis, solar energy, wind energy, technology for generating electricity benefits. I mean, there's so many areas that the rural areas could be used for, for benefit, agricultural, special agricultural growing, building material construction, you know, plants that build building materials on and on and on. So we're looking at the Opportunity Zones, especially rural areas where you're located. You don't, they, you know, need to be retail. You don't need be New York City, just need to be near transportation would be very viable to pick areas that are totally undevelopable. That would have no value, but for the OZ areas.
Jack: Mmmm Hmm.
Ronnie: And that there's where there's a real benefit is, and by the way, there's other areas I want to mention. I'll give you a great area that I'm hoping gets developed south side of Chicago is, an OZ zone.
Jack: Yeah.
Ronnie: But the good part is it needs the help. The bad part is it's not easy to develop there and the government's going to have to give incentives to get people in there because of the difficulty of the area. But that's an OZ zone, a big OZ zone in Chicago.
Jack: Yeah.
Ronnie: So yes, you're seeing that's where the program can become very vital if the governments can figure out how to encourage people and give subsidies to really develop an area, like you said earlier, that they wouldn't develop.
Jack: Yeah. Well, I think we've demonstrated your expertise in the realms of tax law. Let's find out a little bit about Ronnie Fieldstone. The man I saw, I stumbled across something that tickled my fancy, I think you are a supporter of the Actors Playhouse, is that correct?
Ronnie: Yeah, it's a very good facilities nonprofit. That's, it has a partnership with the city of Coral Gables, which is a beautiful area Miami. And they do tremendous production for the benefit of the community for 30 years, a large facility. And so I'm very active in that organization together with a few healthcare facilities that are very active in the healthcare space. So you got to give back somehow. It's important.
Jack: I've got a daughter who's an actress, you know, we grew up, she grew up in a family where we had to be involved in the theater. And I don't mean that we regret it. We love live theater, but one of the things that we learned is almost, there's very little theater that actually pays for itself. So, it's pretty cool to find the people who are helping to keep that art form alive.
Ronnie: Well, they do. I mean, and in Florida, I know they have grants and a lot of these theaters are nonprofit and they wouldn't survive. You're 100% right without grants and government subsidies and the city of Coral Gables, giving free rent for the building because they own the building. It would never work. You can't make me, you're absolutely correct and make it affordable for them, for the public and provide. As you say, they not only give, they give school children come in and they do this, they make it available for community events in particular schools, schoolchildren and summer programs, students and young actors and actresses that want to get trained and get into plays. A great program.
Jack: Well, I like to ask my favorite question. It's a lot of fun because we find out a little bit more about you as a person. I want you to imagine now for a moment that you've won the lottery and you get to the winnings for this particular lottery. You get to be king of the world for one day. So, you're limited to one day, but you are the king of the world and you get to solve one problem. So as king of the world for a day, what's the one problem you're gonna focus your powers on?
Ronnie: Oh, clear. I mean, so many poverty in the world. World poverty would be the number one. That's the biggest crime in our society and the world. What do we do about, because I've traveled to many countries around the world and it's just disgraceful, not just in the world, but also in our country too. But we got to solve that problem. To me, that's maybe the number one, but including the healthcare issues that go with it. I have a daughter that went to the Peace Corps in Malawi, Africa, and boy, you learn what poverty is when you and I visited there twice. We visited her. So I would say that would be my one area. I mean if you look at the, one of my heroes in life as The Gates Foundation that's made a major play in Africa has made such an impact. So I have, I would, that would be my, that would be my king for the day.
Jack: That's a good one. We've been talking a whole lot longer than I thought we would. I always love these conversations because when I get engaged in them, I lose track of the time. So, I don't want to keep you.
Ronnie: Thank you. It's a pleasure.
Jack: Any, any last words for our listeners before we sign off?
Ronnie: No, I just want to make it, thank you for the opportunity and I want to tell you that I'm very appreciative. One of being involved in the OZExpo program or they were going to be a leader in educating the country in this program because they know how to do it right and put on great conferences. So I'm very happy to be part of that program. But I appreciate what you're doing cause you're exposing in many levels a program and people are still getting educated and learning about how to fit in the program. And this again, the program overall, I think everybody agrees, if it's done right, it was going to be terrific for our society. It's got so many benefits. So I'm really very excited to be involved, it's like a regeneration of something new and it's been very exciting for me. So that would be my final comment.
Jack: I think it is good for all of us. Well, if folks want to get a hold of you, need some help with OZ tax law or any other kind of tax law, what's the best way for them to do that?
Ronnie: Well, and by the way, we do corporate securities and real estate too, we don't just do tax, but I'm involved with a department that does all of it. My email ronald.fiedstone@saul.com. It's easy to find me.
Jack: Very good. If you don't mind me, great. For our listeners, that information will be posted along with the audio on our podcast website. Well for Ronnie Fieldstone, Saul Ewing Arnstein & Lehr, I am Jack Heald for the OZExpo Podcast. Thanks for listening today. Please subscribe to the podcast and you're always updated. Good to talk to you and we will talk to you next time.
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Ronnie: Thank you. Good to be here.
Jack: Good to have ya. So, I try to find out a little bit about my guests before we go into the expertise that you bring to the field. Tell us a little bit about yourself. Where'd you come from? How'd you get here? That kind of thing.
Ronnie: Yeah. Well I was born, I grew up in Toronto, Canada. So, I'm actually a foreigner and not too far away. And I migrated to United States in high school and then as an F1 student went to University of Pennsylvania at the Wharton school and then continued to get my master's degree and my MBA degree at Wharton and my law degree at Penn Law. At which time I actually became a green card resident because I married an American. So that got me my green card. I'm still married by the way. So that worked very well.
Jack: Congratulations.
Ronnie: Thank you. And then when I graduated and I moved to Florida, to start my law practice. I'm in Florida, permanent resident of Florida ever since and seen the tremendous transition of the south Florida area from a kind of a sleepy town to a world class city.
Jack: So, you went through the downturn of 2008. Describe that a little bit both from a professional and a personal experience standpoint?
Ronnie: Well, it was obviously devastating to the economy because the Miami area got hit as bad as what not, it'll because it was such a boom and there was so much overbuilding and zealousness with financing and obviously the way it was very difficult on the economy and there was a total collapse in the real estate market and resulted in a very high unemployment, one of the highest foreclosure rates in the country. Where they actually, they got a foreclosure. Foreclosures were taking two years to get done, it was a very difficult time. And the good news was Miami and south Florida are such resilient economies that they were able to rebound when things started getting better and it all came back starting 2011, 2012.
So, there was a probably about a three-year very bad period. Then it started going upwards and believe it or not, values came back to their norms prior to 2008 and even exceeded those. And we've seen a total regeneration of the local economy to a booming economy. But this time around, much more conservative, much tighter controls on financing. And we're not seeing any real estate collapse whatsoever in the local economy today, and it's still thriving, especially given the fact of the problems and other countries and Miami being a, a haven for residents and citizens coming from many countries, in particular, Latin America, also Europe, Russia, other areas.
So I live in a wonderful dynamic environment, which by the way, recently, there was an article in… Concerning, since we're talking about Opportunity Zones, the a Wall Street Journal had an article in the Wednesday edition entitled "Low Income Tax Breaks Fuel Luxury Developers in Miami". And it talks about Miami being the most prolific city to take advantage of Opportunity Zones, first quarter's sales of development sites in Miami Opportunity Zones grew 45%. So what we're seeing is a very dynamic economy; a very fast growing inner city that was underdeveloped and Opportunity Zone designations so they're extremely viable for development. Which makes Miami one of the really very desirable cities for the OZ program. And given the sophistication and the tremendous access to capital in this market, there's a tremendous amount of activity in these projects going on right now
Jack: Prior to the show you and I we're talking about some of the criticisms of the Opportunity Zone program. We've got a pretty educated and sophisticated audience here, so we don't have to go to the elementary, you know, Opportunity Zones 101. Why don't we dive into that discussion we were having earlier when you were telling me about your daughter and. …
Ronnie: Yeah. Sure. So, so I did, I wrote my first article Opportunity Zones sometime in December of last year. And I gave, I gave a copy to my daughter because it was talking briefly about what a terrific program it was. The benefits for developers and tax incentives and how viable it was, which is true. And my daughter, being an educator, a Harvard-educated educator that teaches teachers at an underprivileged school in the Boston area, she wrote me back saying, “Great program, Dad, but what are you doing for the people in the area? What are they getting out of this program?” And I thought about it and I said, “You know, you're right, I'm gonna, I'm gonna make this a cause celeb and I'm going to research it.”
So, I went and researched every article I could find on Opportunity Zones from a social policy standpoint, and I wrote an article called "Opportunity Zones: Who's opportunity is it really?" And I broke out the analysis done by many publications. Primarily example being the economist in November wrote a very scathing article on Opportunity Zones. And the bottom line was that the legislation and at that time, the first set of regulations that came out in October had absolutely no accountability for the effect on communities and the citizens and residents of the people will live in an Opportunity Zones. Zero.
Unlike other countries or other types of programs like the Empowerment Zone program, which is a successor to that really had some track-ability of what was going on with these programs. Given the fact that federal government's giving tax incentives to encourage people, to put money in Opportunity Zones because of, the theory would be, but for these tax incentives, development may not have taken place.
Well, the reality is the criticism of the program, multiple sentence, No.1, no accountability to no traceability. Three a lot of zones that were designated may have been developed anyways without the benefit of the OZ regulate, regulate legislation and regulations. And they call those re-gentrified areas because when they did the original analysis of eligible Opportunity Zones, they used the old census track information and therefore it was kind of stale. So you have areas that are extremely viable for development that are OZ areas. One questions: “Was that really the intent of the statute originally to enable areas that are being re-gentrified to become OZ areas? That's past news now because the law is the law. The designations are fixed for the time of the 10 year time period, so that's not going to change and therefore we are dealing with what we have and if you look at some of the major metropolitan areas in the country, some areas have particular New York, Manhattan area where you have significant OZ designations in Brooklyn, Long Island City and areas that one would say are terrific areas for development.
They were being developed anyways. A matter of fact, the extreme was the Long Island City, which as we know was going to be a secondary headquarters for Amazon and they changed their position for various reasons, but got substantial criticism from the New York Times when that happens that they even now going to take advantage of the OZ. And that was not intended to benefit Amazon because Amazon was in and now he's out. I'm not suggesting a, they picked long island city because it was an OZ zone, but they got the indirect benefits.
Of course, that's a moot issue now because they elected not to proceed with their headquarters there. But that was a good example. So with another offshoot of this is recognizing the deficiency and the reporting requirements when the new regulations were issued on April 17th this year, the Treasury Department also issued a document called request for information on data collection and tracking for qualified Opportunity Zones.
And in summary, what they're saying is that the government wants, is seeking public input on the development. And I quote public information collection and tracking related to investment in qualified Opportunity Zones. And I continue, they talked about the acts seeking to encourage economic growth and investment in designated distressed areas.
They call it designated distress here by providing tax benefits to taxpayers who invest. The purpose of the information is to track the measure of the effectiveness of the policy and achieving stated goals, while making the investment viable. So the stated of goals was to re-gentrify or regenerate impoverished areas to become more desirable for everybody. But the law itself had no tracking mechanism to determine what effect it had on the community. So this proposal which is being proposed will be required that OZ funds will need to provide data reporting when this becomes published.
Because right now it's a proposal to track items that they, the government and based upon responses received from the audience deem appropriate. For instance, they suggest, I'll give you an example, measure that would signal improved economic development in local target markets and spill over areas. Measures of job creation in distressed communities. You know and things of that nature. So in my analysis of articles, I have focused on a few key factors, or it should be at least factored into the government program big time and at least understanding what's happening. Obviously job creations, number one, OZ projects have to spend money, so by definition they're going to create jobs. The question is how many jobs and where are the jobs going to? Are they going to people outside the OZ zones? Are they going to people inside the OZ zone? Affordable housing. We know that residents are going to be displaced because there's going to be housing.
It's going to be torn down because it's antiquated. I'm not complaining about that, but what's happening to the people in the area? Is subsidized housing going to be made available to these people so that they don't have to leave the area? Increase in services because the lower income population, needs transportation health care or healthy food options, education? Engaging local residents in the process, there's no system now that the local residents have any say what's going to happen. And then the biggest thing is big things are taking advantage of community redevelopment agency grants. Many areas including south Florida, municipalities have a CRA, community redevelopment agencies that provide grants to people that develop businesses or projects in distressed areas. And what role is the municipal and state is going to take in this initiative and the assistants and monitoring clearly that there was no monitoring mechanism to factor this in.
So, I think the government initiative now, the Treasury Department is trying to collect data and that doesn't mean it's required. I want to make that clear. Just because they collect the data. It doesn't mean you as a developer or a sponsor need to necessarily provide jobs, services or the like it, but at least to track the information. Now why are they tracking information? So down the road they determine the success of the program, not just economically to taxpayers who would take advantage of the program, but the communities that was supposed to be the beneficiary of the program. In addition, I think it's going to encourage, and it has encouraged local governments to take an initiative that's very valuable. So, as we speak today, I'm aware of 16 states and the island of Puerto Rico, which obviously is U.S. Territory. They're proposing legislation that if you meet certain requirements, the state will give you benefits in addition to the federal benefits.
That could be grants, it could be sales tax reductions, property tax reductions or other grant subsidy grants if you develop certain products. A lot relates to housing, energy services, jobs, trading. And other things that communities, think are valuable to their residents. So what they're now doing this saying you could, you can get the federal benefits with or without us that we as a municipality or as a state will give you other benefits, if you play ball with us and do something that is beneficial to the community and so that's accountable or you get the ben... That tax, we'll give you extra tax benefits to supplement the federal tax benefits. And I think that's going to be very valuable. And I think that's going to play itself out.
Jack: As a tax attorney, you have clients coming to you. How are you advising them to set up their funds, I'm assuming it’s primarily funds to manage this not-yet-required tracking, or are you?
Ronnie: Well that's two questions. First of all, you have to set up the first, I mean let's understand and I want to make this very clear, the OZ program does not make a bad project good. Because if you don't make any money, you don't get the benefits of the capital gains appreciation tax free. So let's understand one thing, right? You know that the industry is telling everybody, projects have to work no matter what. Projects are not bad, project should not get done.
Ronnie: So the project itself has to make economic sense because if you don't make money what difference does it make?
Jack: Yeah.
Ronnie: You're not getting the capital gains benefits. So I think number one, the first advice to everybody is make sure you have a viable project. The second advice is make sure you structure it right from a tax point of view to get the major tax, OZ tax benefits awarded. The next thing we're advising our clients is to look at all the municipal state benefits that are being offered, independent of the OZ program. That would be a creative to the project, but at the same time, a local benefit is going to be tied to services and benefits for the local community.
So, what I'm seeing, which I like a lot, is the communities are starting to take an active role. Virtually everybody in the country is woken up and understands Opportunity Zones are here and it's relevant. And that's going to be a major player, not just in real estate but a major player in setting up new businesses that could grow in an Opportunity Zone and get tremendous benefits going forward. For example, a lot of your incubator companies, tech companies that aren't retail oriented could just as easily located in the OZ zone is located in a non-OZ zone. If they locate in OZ zone, like if another Google or Facebook or you know, some of these companies come around and they located in those OZ zone and they become very successful, go public.
That Bennett that qualifies under the OZ Program. Could you imagine what a tremendous benefit that is?
Jack: Oh Lord.
Ronnie: Having a startup that becomes very valuable, and so we're seeing people analyze carefully, purposely locating OZ projects or businesses and in OZ zones that don't have to be there, but they realize the potential of growing a business into a mega-business and getting the capital gains appreciation tax free is very valuable. Plus of course the location costs in an OZ zone are going to be less expensive. By definition, you're going into a zone that's not primary and it creates jobs and services and it's good. So I think that's where we're going to see a play.
Obviously, we're going to see real estate plays in re-gentrified areas, big time where you're in a zone where you're next to major development. Like they focused on the Wall Street Journal article I mentioned earlier. They show the high rises in the OZ zone and they're developing new OZ projects right next to it. And you'll say to yourself, how could this be an OZ zone? Look what's going up there. But that's, that's what's going on. That's why the market in particular in downtown Miami is so vibrant because it's generated so much extra traffic because of the tax incentives in areas that were already very valuable for development. But again, and then the other item is by going to the governments, you're going to have to track what you're doing. You're going to have to track it because the government is going to make you.
And the other item is there's a kind of an investor base. I call them, maybe you can call them green investors or people that invest based upon societal benefits. And there are certain funds I'm aware of that actually have set aside money. Then we'll only invest in projects that help the local community. They're not gonna, they just don't want to invest in projects to make money. They want some of their money going into areas that may otherwise not get it because they may want, they may even take a lower return if they can feel it. They believe that this was going to create a community benefit. So that I think there's going to be some societal pressure among wealthy investors. Cause this was mainly going to be wealthy investors who are going to be putting their money in those projects to look at the social benefits.
So, I do believe that if I'm a d, if I'm representing the developer in planning, that I surely would emphasize the social benefits of the program. For instance, when I was at a conference recently and the mayor of Miami, Mayor Suarez showed up. He is a big proponent of Opportunity Zones and he said, which was really valuable. The City of Miami will do anything possible to expedite your processing of all your permits and plans to help you develop your project, you know, with as least red tape as possible. So he made a public statement that he is supporting us and I think you're going to see that across the board, the government officials are going to buy into this. And providing, they like what you're doing and they feel it's benefiting the government or the society, they're going to be very proactive.
So, one, look to government. Many times you'll look at government as being a burden, which it is to some degree and stop in blocking or slowing down the process. OZ developments' governments may be very encouraging and supportive and expedite the process because they recognize it's valuable and the more they can do, they get valuable development that's done the right way, the better it's going to benefit the community. There's one thing that benefits the community, no matter what that I neglected to say. No matter what you do from a social benefit standpoint, you're going to increase the tax base. That's a given the property tax base.
Jack: Right.
Ronnie: And when you increase the property tax base, what do you do? You create more money. Okay. And that money goes to the local government authorities, the government authorities can elect to take that money and put it back and they have the right to do that.
So, to some degree the increase in value, which increases property taxes could go to special programs. That will again try to benefit those people displaced or enable those people displaced to stay in the area and possibly better their lives by getting them jobs, job training, etc. So I know, in some areas, like where I live there's job training incentives those where you train people and you get subsidies from the government, to train people to perform services and the local community if you live in, if the residents live in the area. So I think we're going to see a convergence of all know things. So as an advisor to a sponsor or developer, all of the things should be taken into account.
Jack: Are you familiar with anybody who is making impact tracking part of their, their basic approach to OZ investment yet?
Ronnie: No. Would I say no? I mean, I think it's too new. The government itself is even saying to the public. Please give us a list of the things you think we should track so we can monitor it. So, the government's gonna make you do it because I think that the Treasury Department in the near future is going to issue a guideline. There are guidelines and what they're going to require and if they, if they put it into a system, it's going to be required. And that of course, questions commentators make is that, “Well, how do you enforce it?” Because there there's no penalties.
Jack: Yes.
Ronnie: And they're going to have to pass legislation to enforce it. There's definitely going to have to pass legislation to enforce a type of different issue. But at least they took the road to lead based upon the, I think a lot of the comments from the public and government officials are trying to monitor what it's doing, so again, I think you're going to see a whole combination as part of the process and we're new in the game. People are still trying to understand OZ people are still trying to get their hands around how to do it. The regulations that a lot of people were waiting for just came out a little over two weeks ago, so we're still kind of new in the game as far as figuring out how to do this. There's a lot of people who are on the sidelines until the regulations came out.
Jack: Okay. I talked to a lot of folks in this business as you might imagine, and I'd say easily half of them mentioned the impact that OZ investing is supposed to have. They care about it; it matters to them that it actually has an impact in the zone and positive impact in the zone and not merely return a profit. My guess is the, the tax advantages are not sufficient by themselves to just draw anybody who's trying to make money by definition almost because it's in lower served communities. It's drawing people who are more interested in that kind of thing.
Ronnie: Well let me correct you there. Yes. Ideally what you said is correct. Ideally, but not when you're dealing with re-gentrified zones that are already being developed.
Jack: Ah okay.
Ronnie: And they didn't necessarily need the incentive.
Jack: Very good point.
Ronnie: There's just looking at the deals and saying okay I'm doing this deal anyways. Now I'm really doing the deal because…
Jack: Right.
Ronnie: I can now raise capital cheaper, or more readily because my investors can now get all these benefits that they wouldn't have got on a regular real estate deal or a business deal. So to some degree they're doing it either way. They just got a win. I hate to use the word windfall now. It does encourage more development, maybe more extensive development more timely development. So there is a benefit that I don't want to negate the timely cause your cause you have time to invest the money. The government's put a time clock…
Jack: Yeah.
Ronnie: And its benefits to accelerate the process. So I do believe in the normal courses, the development going on in those, these would have taken much longer. Now it's going to be accelerated because of the laws that are encouraging people to invest our money this year, next year, you know, within a short period of time to get the maximum benefits under the tax law.
I think it's a combination, but it's not like, oh, these deals wouldn't work without OZ benefits. There's many deals that would have worked without OZ benefits.
Jack: Well I think you were, it's obvious talking with your expertise is both deep and broad. As I've looked at your biography, you've got an awful lot of experience outside the realm of tax law as well. Lots of different franchises, Barneys, Blockbuster. Talk a little bit about those. How'd you get into those things?
Ronnie: Well, first I grew up in a business. I have an immigrant business family, so you'll learn when you're younger, when you have an immigrant father who started in the business. It's very telling. And then, um, I was fortunate enough in my law practice to get exposed to, you know, some greater business opportunities that I took advantage of. One being becoming a blockbuster video franchisee for 25 stores long before, um, the technology took over and being involved in a branded coffee chain and then getting involved in real estate of funds for multifamily real estate.
So all of those activities have, it just enabled me to, I think get a better grasp of all the moving parts in a business oriented tax law like OZ that's got tax issues but as a major, major business issues that need to be navigated at the same time. So I enjoy the fact that this was a new activity that's very interesting. Involves, yeah, many facets about business and law. Not just tax, but the real estate, corporate environmental government and then business operations and business opportunities. So it's really, uh, a really broad-based program that has no dollar limit and it's on its base and has a tremendous potential. So I think my, my background has been very helpful.
Jack: Oh, I would think so.
Ronnie: Giving me, you know, the, the ability to just appreciate and try to take advantage of what's available.
Jack: If you don't mind. Let's talk about the cannabis industry and its intersection with Opportunity Zones. I see that Saul Ewing Arnstein & Lehr is involved in the cannabis law area as well. What are your thoughts in that regard?
Ronnie: Yeah, well it's very good. First you have cannabis and then CBD, which is hemp. So the distinguishing factor in CBD hemp is, it is not deemed a drug. It doesn't have any federal restriction. As we know cannabis technically it's, the industry itself is against federal law, but it's not being enforced. And you have, I think 30 states now that have a cannabis law either for medicinal or recreational purposes. So the issue became very interesting when the first regs came out, when the law came out, and then the regs, a law came out? They have what's called sin activities.
Jack: Mmm, Right.
Ronnie: And there's certain activities excluded items like a massage parlors and liquor stores and golf courses and things that they're, not that they're bad moral judging that, but they said we're not, we're not going to let you benefits of the program to do these, what we call sin activities. And they listed them. It was about six or seven.
Jack: Right.
Ronnie: They did not put cannabis in there. They could have and they didn't. Yeah. One would argue, well it's illegal federally anyways, they didn't have to put it in. One would also argue, wait a minute, they could have put it in because there was restrictions on alcohol. There's restrictions on this. So the alcohol’s highly regulated and there's limitations on that. So, they could have put it in if wanted to.
And the answer was they didn't put it in. So one could argue the, and the people who are concerned with a federal, the IRS respect a cannabis business. It's in an OZ zone because it's not legal under federal law, but there are also federal laws, tax laws that excluded cannabis businesses from certain benefits. You can't take a loss, you can't get certain credits. So why would the IRS have special tax laws for the cannabis industry?
Which means you report your income and you pay tax on it. Even though technically it's violating federal law. Well at the same time excluded from OZ world. So we believe there is no reason that this time to believe cannabis will be excluded. If they wanted to exclude it, they would have excluded it. Now maybe there'll be future legislation that will exclude it.
Jack: Right.
Ronnie: So right now, it's not excluded, and we believe since it's not excluded, it should be viable. Now, don't forget, you have two types of cannabis. You have medicinal, which is a lot of the states, and you have recreational, which is a much smaller number of states. One could easily argue that from a medicinal purpose. It's got a great benefit to society. In my state, Florida. It after the second round, did past by a large margin as a medicinal use.
Ronnie: And most people do it, the substantial majority of the population and forward a view it as a benefit to society for all the right reasons.
Jack: Right.
Ronnie: So why would you then prejudice that type of business from any other business. Growing? You can grow, you know, um, agriculture people are talking about special hydroponics, power plants, energy as solar, you know, all things that benefit society. You know, I'm not making a moral judgment of cannabis should not be in that, that would not apply to CBD at all CBD would not be, and it should be because CBD is not a drug. And as you may or may not know, but CVS and Walgreens just announced they're putting CBD in a you know, substantial number of their stores. So nobody's questioning CBD at all. Cannabis, different story. So we believe it should be. Right now our people are telling us they're not looking at cannabis any different than because of OZ. As a matter of fact, it's opportunistic for OZ.
Jack: Seems like.
Ronnie: Because cannabis farms in areas that are OZ designated.
Jack: I was going to say; it seems like a natural fit for some of the rural areas. As far as I understand it, marijuana is a relatively difficult plant to grow, but people who know how to do it might be able to make it work.
Ronnie: They seem to be growing it all over the countries, states in the rowing it
Jack: I can kill anything green. So, you know, everything's hard for me.
Ronnie: No, but you're, you're well stated. But the rural areas, not just cannabis, solar energy, wind energy, technology for generating electricity benefits. I mean, there's so many areas that the rural areas could be used for, for benefit, agricultural, special agricultural growing, building material construction, you know, plants that build building materials on and on and on. So we're looking at the Opportunity Zones, especially rural areas where you're located. You don't, they, you know, need to be retail. You don't need be New York City, just need to be near transportation would be very viable to pick areas that are totally undevelopable. That would have no value, but for the OZ areas.
Jack: Mmmm Hmm.
Ronnie: And that there's where there's a real benefit is, and by the way, there's other areas I want to mention. I'll give you a great area that I'm hoping gets developed south side of Chicago is, an OZ zone.
Jack: Yeah.
Ronnie: But the good part is it needs the help. The bad part is it's not easy to develop there and the government's going to have to give incentives to get people in there because of the difficulty of the area. But that's an OZ zone, a big OZ zone in Chicago.
Jack: Yeah.
Ronnie: So yes, you're seeing that's where the program can become very vital if the governments can figure out how to encourage people and give subsidies to really develop an area, like you said earlier, that they wouldn't develop.
Jack: Yeah. Well, I think we've demonstrated your expertise in the realms of tax law. Let's find out a little bit about Ronnie Fieldstone. The man I saw, I stumbled across something that tickled my fancy, I think you are a supporter of the Actors Playhouse, is that correct?
Ronnie: Yeah, it's a very good facilities nonprofit. That's, it has a partnership with the city of Coral Gables, which is a beautiful area Miami. And they do tremendous production for the benefit of the community for 30 years, a large facility. And so I'm very active in that organization together with a few healthcare facilities that are very active in the healthcare space. So you got to give back somehow. It's important.
Jack: I've got a daughter who's an actress, you know, we grew up, she grew up in a family where we had to be involved in the theater. And I don't mean that we regret it. We love live theater, but one of the things that we learned is almost, there's very little theater that actually pays for itself. So, it's pretty cool to find the people who are helping to keep that art form alive.
Ronnie: Well, they do. I mean, and in Florida, I know they have grants and a lot of these theaters are nonprofit and they wouldn't survive. You're 100% right without grants and government subsidies and the city of Coral Gables, giving free rent for the building because they own the building. It would never work. You can't make me, you're absolutely correct and make it affordable for them, for the public and provide. As you say, they not only give, they give school children come in and they do this, they make it available for community events in particular schools, schoolchildren and summer programs, students and young actors and actresses that want to get trained and get into plays. A great program.
Jack: Well, I like to ask my favorite question. It's a lot of fun because we find out a little bit more about you as a person. I want you to imagine now for a moment that you've won the lottery and you get to the winnings for this particular lottery. You get to be king of the world for one day. So, you're limited to one day, but you are the king of the world and you get to solve one problem. So as king of the world for a day, what's the one problem you're gonna focus your powers on?
Ronnie: Oh, clear. I mean, so many poverty in the world. World poverty would be the number one. That's the biggest crime in our society and the world. What do we do about, because I've traveled to many countries around the world and it's just disgraceful, not just in the world, but also in our country too. But we got to solve that problem. To me, that's maybe the number one, but including the healthcare issues that go with it. I have a daughter that went to the Peace Corps in Malawi, Africa, and boy, you learn what poverty is when you and I visited there twice. We visited her. So I would say that would be my one area. I mean if you look at the, one of my heroes in life as The Gates Foundation that's made a major play in Africa has made such an impact. So I have, I would, that would be my, that would be my king for the day.
Jack: That's a good one. We've been talking a whole lot longer than I thought we would. I always love these conversations because when I get engaged in them, I lose track of the time. So, I don't want to keep you.
Ronnie: Thank you. It's a pleasure.
Jack: Any, any last words for our listeners before we sign off?
Ronnie: No, I just want to make it, thank you for the opportunity and I want to tell you that I'm very appreciative. One of being involved in the OZExpo program or they were going to be a leader in educating the country in this program because they know how to do it right and put on great conferences. So I'm very happy to be part of that program. But I appreciate what you're doing cause you're exposing in many levels a program and people are still getting educated and learning about how to fit in the program. And this again, the program overall, I think everybody agrees, if it's done right, it was going to be terrific for our society. It's got so many benefits. So I'm really very excited to be involved, it's like a regeneration of something new and it's been very exciting for me. So that would be my final comment.
Jack: I think it is good for all of us. Well, if folks want to get a hold of you, need some help with OZ tax law or any other kind of tax law, what's the best way for them to do that?
Ronnie: Well, and by the way, we do corporate securities and real estate too, we don't just do tax, but I'm involved with a department that does all of it. My email ronald.fiedstone@saul.com. It's easy to find me.
Jack: Very good. If you don't mind me, great. For our listeners, that information will be posted along with the audio on our podcast website. Well for Ronnie Fieldstone, Saul Ewing Arnstein & Lehr, I am Jack Heald for the OZExpo Podcast. Thanks for listening today. Please subscribe to the podcast and you're always updated. Good to talk to you and we will talk to you next time.
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