Structuring a QOZ Fund & QOZB for Ground-Up Development – Columbus, OH

[Robert Ellis]

I’m looking into the best way to structure a Qualified Opportunity Zone (QOZ) Fund and a Qualified Opportunity Zone Business (QOZB) for ground-up construction and land entitlement in Columbus, Ohio for hotel and multifamily development. We target land plots that can make a minimum 5x equity bump or return on equity spend within 6 months and those would be sold out of the QOZB land fund. 

I know that a QOF can invest directly in real estate, but I’m particularly interested in the QOZB structure, since it allows for active business operations and working capital flexibility.

For those who have set up a QOZB:

• How did you structure it in relation to your QOF?
• Was your QOZB designed for a specific state/city, or was it structured to operate more nationally?
• What challenges did you encounter in fund formation, compliance, or deal structuring?
• Any best practices for structuring a QOZB for real estate development in Columbus, OH?

I’d appreciate any insights, lessons learned, or recommendations from those who have gone through this process. Looking forward to the discussion!