Opportunity Funds

We intend to file with the Internal Revenue Service (“IRS”) to become a qualified Opportunity Fund (“QOF”). There is no guarantee that any investor would be able to realize any particular tax results by making an investment in us. Limited Internal Revenue Service guidance and proposed Treasury Regulations have been provided but there is still uncertainty regarding the Opportunity Zone program. Although the US Department of the Treasury has released guidance on the Tax Cuts and Jobs Act of 2017 (“TCJA”), there is no guarantee that the rules of the program will not be changed in the future. Each prospective investor should consult with their personal tax advisors before making any investment into an QOF including the OZFund.

OVERVIEW – The Tax Cuts and Jobs Act (TCJA) provides that, for investors who have rolled capital gains into an opportunity fund or invest in a QOF and hold that investment in the QOF for a period of ten years or more, that any additional appreciation beyond the amount initially invested realized by such investor from liquidating such investment will not incur additional federal capital gains taxes. However, each prospective investor should consult with their personal tax advisors before making any investment into an QOF including the OZFund.
DEFER CAPITAL GAINS – Section 1400Z-2(b)(1) states that capital gains rolled into an Opportunity Fund by an electing investor generally within 180 days of being realized shall be included in taxable income I the taxable year that includes the earlier of the disposition of the Opportunity Fund investment and December 31, 2026.

REDUCE TAX YOU OWE – Section 1400Z-2(b)(2)(B) states that an investor’s basis in the capital gain rolled into an opportunity fund is initially zero and that an investor will receive, a step up in basis of 10% of the deferred gain initially invested if held for at least five years. Note, however, that as the deferred capital gain will be taxed on December 31, 2026, we expect that these holding periods would need to be satisfied prior to that date in order to receive the maximum benefits described herein. The TCJA provides that, for investors who have rolled capital gains or invested in a QOF and hold that investment in the QOF for a period of ten years or more, that any additional appreciation beyond the amount initially invested realized by such investor from liquidating such investment will not incur additional federal capital gains tax. However, please note that, given the uncertainty regarding future Treasury Department guidance, prospective investors should consult with their tax advisor before making any investment into a QOF including the OZFund. This website is not an offer to sell nor a solicitation to buy Securities. That can only be done by our current confidential Private Placement Memorandum (“PPM”). Investing in the OZFund is considered a speculative investment for accredited investors only, who can stand to lose their entire investment. The equity interests being sold in this offering have not been approved or disapproved by the Securities and Exchange Commission or any state’s securities division. Nor has the Securities and Exchange Commission or any state securities department passed upon the accuracy or adequacy of the PPM or the disclosures provided therein.