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Can a QOF capitalize another QOF?

I am starting a QOF but was wondering if another QOF can capitalize my deals if it is attractive to their investors?


Answers
  • Brad Cohen
    June 02, 2020

    No, but there are ways to get around it.

  • Matt Campbell
    June 02, 2020

    No, a QOF can't fund another QOF. A QOF can invest in another QOF's QOZBs, however.

  • Samuel Weiser
    June 02, 2020

    No. A QOF can not invest in another QOF.

  • Neil Faden
    June 02, 2020

    No. A QOF must invest in Qualified Opportunity Zone property or businesses. Another QOF can invest alongside your QOF though.

  • Matthew Rappaport
    June 03, 2020

    QOFs are not allowed to invest in other QOFs.

  • Scott McIntosh
    June 02, 2020

    A QOF cannot invest in another QOF, however, multiple QOFs can invest in the same QOZB. In most substantial OZ developments, it makes sense to have both a project-specific QOF that can accept recently-realized capital gains from investors, as well as a QOZB that is structured to accept investment from both your project-specific QOF as well as other outside QOFs. Most of my clients choose to build in their fee and promote structures at the QOZB level so that those terms apply equitably across the several QOFs that invest in the deal.

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