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How does the 31 months safe harbor plan work on an asset by asset basis?

If at the time of passing cash from a QOF to a QOZB I have a specific plan for some properties but not all funds, how do I write the WCSH? My plan is to write the specific part specific and the general part general. As I acquire properties with their own business plan I will update the WCSH. Is this plan sufficient? I will definitely deploy all capital within 31 months period and be using loans for final development.


Answers
  • Matthew Rappaport
    December 01, 2021

    There aren't any hard guidelines for a WCSH business plan, so as long as your approach is reasonable, it should be fine. It has to detail the way capital will be spent and a timeline for spending it; we usually advise clients to go quarter-by-quarter. But there's no specific template, no IRS form, nothing concrete to tell you how it needs to look and how it needs to be organized. I'd at least run your draft by counsel, though.

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