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Opportunity Zones · Structure

Land is the most expensive dollar in an OZ basis.

Opportunity Zone rules push capital toward improvements rather than dirt, and OZ deals run against deadlines. Both facts point the same direction on the land.

The substantial improvement test is measured against the building, not the land.
OZ rules generally exclude land from the basis that must be substantially improved. Land still has to be paid for, still consumes equity, and still earns nothing until the project stabilizes — but it does not help satisfy the test the fund is being measured on.
The clock

OZ deals fail on timing more than on economics.

A qualified fund has deployment deadlines and a working capital safe harbour with a defined window. A project that stalls waiting for an equity close does not simply cost more, it can put the fund's own compliance at risk.

Which makes a capital source that reduces the raise more valuable in an OZ deal than in a conventional one. It is not only cheaper money, it is less money to find inside a fixed window.

How it fits

The fund holds the leasehold. We hold the dirt.

We buy the land at closing and lease it back for 99 years, unsubordinated. The QOZB holds the leasehold and the improvements, keeps the depreciation, and keeps every dollar of appreciation. The equity requirement drops by the land price on day one.

Structure and eligibility are fact-specific and depend on how the fund and the operating business are organised. Run the structure past OZ counsel before relying on it — we are a principal, not a tax advisor, and we will not tell you it qualifies. What we will do is price the land so your counsel has a real number to work against.

Questions, answered

FAQ.

Does the land count toward substantial improvement?

Generally no. That is the point of the question. Confirm with OZ counsel for your specific structure.

Can the QOZB be the ground tenant?

That is the usual shape. Confirm eligibility with counsel; we do not give tax advice.

Does the deadline pressure change your process?

It changes the sequencing. Tell us the date you are working to and we will say plainly whether it is achievable.

What do you need to price it?

As-complete stabilized NOI, total project cost, market and asset type.

Can you close in an OZ window?

Depends on the window. We are a principal with no outside committee, which removes the slowest part, but title, appraisal and lender timing still apply.

Get your number

Tell us the deadline first.

Stabilized NOI, total cost, and the date you are working to. We will tell you whether the land number helps and whether the timing is real.

Email us the property