Among other things, “qualified opportunity zone property” includes investment in “original use” property (e.g. new construction) or, if the property has been previously used, “substantial improvement” of such property. Property is considered to have been “substantially improved” only if, during any 30-month period beginning after the acquisition of such property, the tax basis of such property exceeds an amount equal to the adjusted basis of the property at the beginning of the 30-month period.
Qualified Opportunity Funds are required to hold 90% of their assets in “qualified opportunity zone property,” and that test is given to each fund 6 months after the tax year begins and at the end of each tax year. Since there is no indication as to how fast funds must deploy capital in order to meet this 90% limit, the Manager intends to invest funds as soon as reasonably possible, with the intention of having a project pipeline which facilitates the same; or to adhere to any timeline set forth required by applicable law, regulations, or other guidance as it pertains to the Manager’s responsibility for meeting the 90% requirement.