Our process
A disciplined process for a ten-year commitment
Opportunity Zone compliance runs for a decade. Our process is built for that: clear scope at the start, consistent oversight in the middle, and a complete record at the end.
The engagement
How we work with you
Introductory conversation
A confidential discussion of your project, timeline and existing advisors. We’ll tell you plainly whether and how we can help.
Project review
We review the structure, documents, tract information and capital plan, and identify gaps or risks for your counsel to consider.
Scope and compliance plan
A written scope of work and a compliance plan for the project: what will be tested, tracked and reported, by whom and when.
Onboarding
We set up the compliance file, the reporting calendar and the data flows from your accounting and project teams.
Ongoing oversight
Testing, monitoring, investor reporting and filing support, period after period, with early warning when something needs attention.
Exit
A complete, documented compliance history and coordinated support for your advisors through exit and wind-down.
The ten-year lifecycle
What happens, and when
OZ 2.0 rules, for investments made after December 31, 2026. Simplified; your counsel will confirm how they apply to your project.
Day 0
Gain, investment and structure
Eligible capital gain is invested in a qualified opportunity fund within the 180-day window. The fund and business structure, tract and capital plan are set.
§ 1400Z-2(a)
Months 1–31
Capital deployment
Cash held by the business is deployed under a written working-capital plan and schedule. The safe harbor allows up to 31 months, documented as spending happens.
Treas. Reg. § 1.1400Z2(d)-1
Months 1–30
Substantial improvement
Existing property must be substantially improved: within any 30-month period, additions to basis must exceed its adjusted basis at the start of that period, or 50% of it for property in entirely rural zones.
§ 1400Z-2(d)(2)(D)
Every six months
Fund testing
The fund’s 90% asset test is measured twice a year, on the last day of the first six-month period and the last day of the taxable year.
§ 1400Z-2(d)(1)
Every year
Reporting
The fund files its expanded annual return, and each business furnishes its statement to the fund. Records behind both are kept current through the year.
§§ 6039K, 6039L
Year 5
Gain recognition and step-up
Under OZ 2.0, deferred gain is included five years after the investment (or earlier on a sale), after a 10% basis increase, or 30% in a qualified rural opportunity fund.
§ 1400Z-2(b)
Years 6–9
Stewardship
Testing and reporting continue. Refinancings, distributions and changes to the business are reviewed for their compliance impact before they happen.
§ 1400Z-2(d)
Year 10+
The long-term election
After ten years, an investor may elect to treat the investment’s basis as its fair market value when it is sold, subject to the 30-year limit.
§ 1400Z-2(c)
Principles
What you can expect from us
- Plain answers
- We say what we see, including when something needs your counsel’s attention.
- Documented work
- Every test and conclusion is supported by workpapers you can hand to an auditor.
- No surprises
- Dates, deliverables and responsibilities are set out in advance, every period.
- Clear boundaries
- We don’t give legal or tax advice. We make sure the people who do have what they need.
Talk to us before the structure is set.
Whether you’re forming a new fund or bringing an existing project into compliance, we’ll tell you plainly where you stand.