68 OPPORTUNITY ZONE MAGAZINE | ISSUE 2 • VOLUME 2
VALERIE GRUNDUSKI
PLANTE MORAN
As a real estate tax specialist and partner at Plante Moran , Valerie Grunduski advises clients on planning concerns related to purchases and sales , partner buy-outs and redemptions , tax and debt structuring , historic tax credits , and other community development incentives . She consults with clients on how to best utilize the new Opportunity Zone incentive . As the firm leader of this investment vehicle , she works with those seeking to create Opportunity Zone funds and is involved in a coalition to help policymakers shape regulations and legislative corrections . Grunduski regularly speaks about the program to associations and at conferences .
WHAT NEW TAX CHANGES IMPACTING THE OPPORTUNITY ZONE INDUSTRY CAN WE EXPECT IN 2022 ?
Anyone who follows the news out of D . C . knows that we face an uphill battle trying to predict what tax law changes are on the horizon – but we can at least make an educated guess ! Given the impact that the OZ incentive has made in a relatively short time , I would love to see measures that allow the program to be extended beyond its current planned expiration . This could be in the form of an extension of the 2026 deferral period – there are currently many calls for an extension to 2028 – or result in a new round of QOZ designations and investment periods . Beyond an extension , proposed changes in rates could really supercharge the 10-year holding period benefit .
MARK LEEDS
MAYER BROWN
Mark H . Leeds is a tax partner with the law firm of Mayer Brown . His professional practice focuses on the tax consequences of a variety of investments , capital markets products and strategies , including Qualified Opportunity Funds . Leeds has worked on QOF structures for real estate projects and operating businesses . Prior to joining Mayer Brown , he was a managing director with Deutsche Bank AG in New York . Leeds is also a recipient of the 2015 Burton Award for Distinguished Legal Writing .
WHAT NEW TAX CHANGES IMPACTING THE OPPORTUNITY ZONE INDUSTRY CAN WE EXPECT IN 2022 ?
It appears very unlikely that Congress will pass any statutory changes to the QOZ rules in 2022 . It is much more likely that the Internal Revenue Service will continue to provide regulatory guidance on the issues facing QOFs in 2022 . My best bet is that the IRS will promulgate rules requiring disclosure of local impact of projects for which QOF benefits are claimed . Other issues ripe for consideration are the tax considerations applicable to changing projects if a specified project becomes unavailable , rules for QOZBs engaging in joint ventures and new rules for businesses that trade assets treated as commodities .
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