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Qualified Opportunity Zone (QOZ) Partnership

A Qualified Opportunity Zone (QOZ) Partnership is a significant concept in the Qualified Opportunity Fund (QOF) industry, part of a U.S. tax incentive to encourage investment in economically distressed communities, known as Qualified Opportunity Zones (QOZs). While there isn’t a standard definition titled “QOZ Partnership,” I can provide information based on the underlying concepts related to QOFs and QOZs.

A QOZ Partnership refers to a partnership (or another entity taxed as a partnership) that invests in eligible property located in a QOZ. It becomes part of the equation when individuals or corporations aim to invest in a QOZ through a QOF. Here’s a breakdown of how it typically works:

  1. Investment in a QOF: Investors who have capital gains from other investments can invest those gains into a Qualified Opportunity Fund. The QOF is an investment vehicle organized as a corporation or a partnership.
  2. QOF Investment in QOZ Property: The QOF must hold at least 90% of its assets in QOZ property, which includes business property, stock, or partnership interests in businesses that operate in a QOZ.
  3. QOZ Partnership as a Vehicle: If a QOF invests in a QOZ Partnership, this partnership should conduct a trade or business within the QOZ, and a substantial part of its owned or leased property should be within the QOZ.
  4. Tax Benefits: Investors in a QOF can defer and potentially reduce their capital gains taxes, and if they hold the investment for at least ten years, they may eliminate capital gains taxes on the appreciation of the QOZ investment.

So, a QOZ Partnership essentially is a partnership entity that is part of the structure allowing investors to gain tax benefits by investing their capital gains in economically distressed communities, in accordance with the guidelines set by the Opportunity Zone legislation.