Architect Submits Questions on O-Zone Regs

PUBLIC SUBMISSION

Docket: IRS-2019-0022
Investing in Qualified Opportunity Funds (REG-120186-18)

Comment On: IRS-2019-0022-0001
Investing in Qualified Opportunity Funds [REG-120186-18]

Document: IRS-2019-0022-0013
Comment from Edward McGinnis, ERM architecture LLC

Submitter Information

Name: Edward McGinnis

Address:

6 Burns Street
#416
Forest Hills, NY, 11375

Email: ERMarchitecture@aol.com

Phone: 917-650-3372

Fax: NA

Submitter's Representative: Ed McGinnis

Organization: ERM architecture LLC

Government Agency Type: Local

Government Agency: NA

General Comment

Can an investor withdraw $ at any time? Cap gains would be on a sliding scale?

Dec 2019 is deadline for contributing $ for a full elimination of Cap Gains if held 10 Years?

How much time is needed to set up a Fund?

Does an investor in a Fund created by someone else become a 'partner' for the profits/losses? Kind of a REIT?

Is a fund similar to a mutual fund whence anyone can invest in?

Are there profits and losses similar to mutual funds?

Does an investor become a 'partner/stock holder' in the fund?

Cap gains must be contributed within 180 days?

Can a seller of property that becomes the base of the OZF invest cap gains into fund established by developer?

Such would be great incentive to sell. Requires developer's concurrence?

If an investor withdraws contributed gains before 10 years, he is responsible for cap gains taxes beginning when?

Fund must break ground within 31 months of formation? Is this the 'safe harbor?'