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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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Can a Qualifying Opportunity Zone Fund (QOF) structure be established with non-capital gain dollars and then such nonqualifying interests be sold at any future point before 2027 by the original investors to persons who have capital gain dollars and become eligible qualifying interests?  According to a recent statement by a Treasury attorney at a Federal Bar Association meeting, the answer would be yes.  If accurate and confirmed by future clarifying guidance, this raises a series of questions and additional opportunities. <a href="https://admin.thompsonhine.com/wp-content/uploads/1135/doc/QualifyingQOFInterests.pdf" target="_blank" rel="noreferrer noopener">Read more.</a>

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For more information, please contact Frank Ferrante, Alexis Kim, or any member of the firm’s <a href="https://www.thompsonhine.com/services/qualified-opportunity-zones" target="_blank" rel="noreferrer noopener">Qualified Opportunity Zones group.</a>

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Francesco A. Ferrante Thompson Hine LLP Phone: 937.443.6740 Mobile: 937.470.0598 <a href="mailto:Francesco.Ferrante@ThompsonHine.com">Francesco.Ferrante@ThompsonHine.com</a>

Alexis J. Kim Thompson Hine LLP 3900 Key Center 127 Public Square Cleveland, OH 44114 Phone: 216 566-5732 Mobile: 216-385-3493 <a href="mailto:Alexis.Kim@ThompsonHine.com">Alexis.Kim@ThompsonHine.com</a>

https://admin.thompsonhine.com/wp-content/uploads/2022/04/QualifyingQOFInterests.pdf

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Senior Managing Associate

Alexis J. Kim

Treasury Comment Introducing Approach for Purchasers of Non-Qualifying QOF Interests to Have Qualifying QOF Interests