There are a few alternatives for combining Qualified Small Business Stock with Opportunity Zones. An investor can invest directly into a C corporation that will be both a qualified small business and a qualified opportunity fund. Alternatively, the investor can invest into a partnership, which will be a qualified opportunity fund and hold an interest in a C corporation that will be the qualified small business and a qualified opportunity zone business. Either structure should give the investor the ability to defer/exclude invested gain under the opportunity zone rules and exclude future appreciation from a disposition of the qualified small business stock after five years, under Code Section 1202. The structures also have a "belt and suspenders" benefit, in a case where the entities fall out of compliance with one regime but not the other.
