『QOZ 2.0 & Complex 1031 Exchanges - The Best Strategy for 2027 and Beyond』のカバーアート

QOZ 2.0 & Complex 1031 Exchanges - The Best Strategy for 2027 and Beyond

QOZ 2.0 & Complex 1031 Exchanges - The Best Strategy for 2027 and Beyond

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Episode SummaryTax attorney and CPA Austin Carlson of Gray Reed breaks down partnership 1031 strategies (drop-and-swap, PIN notes, TICs) and the new Opportunity Zones 2.0 program made permanent under the One Big Beautiful Bill Act. If you own real estate with partners or are planning a business exit, this episode lays out the structures wealthy investors are using to defer — and often eliminate — capital gains tax.Key Takeaways• Solo 1031s are simple. Partnership 1031s require careful planning. When partners have different goals, involving a tax attorney early can help avoid costly mistakes.• A “Drop and Swap” separates partner interests before a sale. Some partners can cash out while others complete their own 1031 exchanges. The IRS closely examines timing and intent.• A Partnership Installment Note (PIN) can help when timing is tight. It allows an exiting partner to receive most proceeds upfront while keeping the partnership intact.• QOZ 2.0 expands tax benefits beyond real estate. Beginning January 1, 2027, gains from real estate, businesses, crypto, and art may qualify for Opportunity Zone benefits.• QOZs preserve basis, while 1031s require full reinvestment. Investors only need to reinvest the gain in a QOZ, which can provide greater liquidity.• A Qualified Opportunity Fund (QOF) can be a backup plan. If a 1031 exchange falls through, a QOF may provide an alternative way to defer gains.Chapters00:00 Intro: Partnership Structuring, OZ 1.0 vs. OZ 2.000:47 Meet Austin Carlson (JD, CPA)02:00 Tax Attorney vs. Accountant04:35 When to Involve a Tax Attorney in a 103107:55 "Drop and Swap" Strategies Explained10:30 Partnership Exit Scenarios and Loan Challenges14:00 Partnership Installment Note (PIN Note)17:55 IRS Intent Rules and Partnership Considerations20:00 When a Tax Attorney Is Worth the Cost23:00 Case Study: $50M Texas Ranch Exchange26:30 Opportunity Zones for Art, Business, and Real Estate Gains28:20 QOZ Origins and Evolution31:00 1031 Exchanges vs. Opportunity Zones35:30 Core QOZ Benefits: Defer, Reduce, Eliminate38:00 QOZ 2.0 and Permanent Tax Incentives40:30 Deferral, Basis Step-Up, and Tax-Free Growth Explained43:00 $1M Gain Example Breakdown44:30 New QOZ Maps and Substantial Improvement Rules47:30 QOZ vs. 1031: Which Strategy Wins?52:00 Timing Rules, K-1 Extensions, and 180-Day Deadlines54:30 Using a QOZ as a Backup for a Failed 103156:00 Creating Your Own Opportunity Zone Fund58:00 Existing Property Owners in Opportunity Zones1:00:00 Wrap-Up and Future DiscussionAbout the GuestAustin Carlson, JD, CPAPartner | Gray Reed & McGraw LLP | Houston, TexasAustin is a tax attorney and CPA at Gray Reed, focused on complex real estate structuring, partnership planning, 1031 exchanges, Opportunity Zone funds, and M&A. Named Houston CPA Society’s “Young CPA of the Year” and a Texas Super Lawyers Up-and-Coming 100 honoree, he serves on the Texas Society of CPAs Federal Tax Policy committee and works nationally with sponsors, family offices, and business owners on transactions from a few million to nine figures.Connect with Austin: grayreed.com/our-people/austin-c-carlsonKeywordsPrimaryOpportunity Zones 2.0 • One Big Beautiful Bill • Drop and Swap 1031 • 1031 exchange partnership • Qualified Opportunity Fund • OZ 2.0 • capital gains deferral • OBBBA opportunity zonesSecondary & Long-TailSection 1031 • TIC exchange • PIN note • partnership installment note • swap til you drop • QOF • OZ vs 1031 • sell business defer capital gains • baby boomer business exit • new opportunity zone map 2026 • build your own opportunity zone fundTagsreal estate, passive income, tax strategy, 1031 exchange, opportunity zones, partnership tax, real estate law, M&A, business exit, capital gainsDisclaimerThis is for informational purposes only, does not constitute individual investment advice, and should not be relied upon as tax or legal advice. Please consult the appropriate professional regarding your individual circumstance.Because investor situations and objectives vary this information is not intended to indicate that an investment is appropriate for or is being recommended to any individual investor.There are material risks associated with investing in private placements, Delaware Statutory Trusts ("DSTs") and real estate securities including the potential loss of the entire investment principal, illiquidity, tenant vacancies impacting income and revenue, general and real estate market conditions, lack of operating history, interest rate risks, competition, including the risk of new supply coming to market and softening rental rates, general risks of owning/operating commercial and multifamily properties, short term leases associated with multi-family properties, financing risks, potential adverse tax consequences, general economic risks, development risks, long hold periods, and investors should read the PPM carefully before investing paying special attention to ...
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