My QOZB will develop and rent out real estate in an OZ, all property ownership will be within an OZ. However, the QOZB business address (a registered agent) will be outside the zone and there will be no employees as contractors and property managers will not be employees.
It sounds like you've read up on the safe-harbor requirements for determining whether a QOZB generates at least 50% of its income from "activities within the Opportunity Zone." Based on what you've described, it appears your operations won't fit neatly into one of those safe harbors. That said, you seem to clearly meet the 'facts and circumstances" test, given that 100% of the company income will be generated by rental properties located in the Opportunity Zone.
No, a qualified opportunity zone business (QOZB) is not required to have an address or employees in an qualified opportunity zone (QOZ).
You can probably justify this under the various safe harbors under the 50%-of-income requirement or, at worst, the facts-and-circumstances catchall.
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