Tribal governments can benefit from Opportunity Zones through utilization of the ground lease structure.
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How can tribal governments benefit from Opportunity Zones?
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There are no special rules for tribal governments. I am no expert on the topic, but it seems that the possibility of leased property being qualified helps these entities.
Since governments pay no income tax, there is no direct benefit to a tribal government, other than if the tribal government had equity in one or more business entities receiving investment from a Qualified Opportunity Fund. If then, the government could benefit. And the government could benefit from the leasing of tribal land/buildings for use by one or more Qualified Opportunity Zone business entities.
I suspect they would not be a federal taxpayer, so most of the benefit would come in the form of economic development on the tribal lands. This is certainly attracting interest from developers, and if any OZ census tracts end up being within their tribal boundaries, this will make the project more attractive.
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