If a C-Corp makes an investment into a QOF and then waits 10 years to exit the investment, the ultimate owner will end up paying dividend tax to get the profit out because it is a C-Corp, correct? Does the QOZ legislation provide any benefit to this type of investor/structure?
To the best of my knowledge, the rules around asset sales still apply to C-Corps, insofar as C-Corps don't need to choose between selling the stock or selling the assets to notch QOZ benefits. But I would not choose a C-Corp as the investment vehicle unless you're taking advantage of Section 1202 or otherwise would like to have institutional capital be your exit strategy. It's a definite no-no for real estate unless you're doing a REIT.
No special treatment for corporate structures is provided within the regulations.
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