Qualified Opportunity Zones & Energy Projects: New Tax Incentivesmedia.straffordpub.com/products/qualified-opportunity... · 2018-10-17 · There are two federal incentives for investments

Qualified Opportunity Zones & Energy

Projects: New Tax IncentivesEligibility Requirements, Formation, Self-Certification,

Favorable Treatment of Returns on Investment

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THURSDAY, OCTOBER 18, 2018

Presenting a live 90-minute webinar with interactive Q&A

Michael D. Haun, Partner, Paul Hastings, Los Angeles

James O. Lang , Shareholder, Greenberg Traurig, Tampa, Fla.

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5

▪ Rev. Proc. 2018-16 detailed the QOZ designation process for

states. The states had until March 21, 2018 to nominate tracts

as QOZs (with the ability to request a 30-day extension). The

Treasury had to certify designations within 30 days after

receiving nominations.

▪ The census tracts that were eligible were “low-income

community census tracts” (“LICCTs”)

▪ Poverty rate of at least 20%

▪ If tract not located within a metropolitan area, median family

income (“MFI”) did not exceed 80% of statewide MFI

▪ If tract located within a metropolitan area, MFI did not exceed 80%

of the greater of statewide MFI or metro area MFI

QUALIFIED OPPORTUNITY ZONES – DEFINED

6

▪ Non-LICCT Tracts

▪ Must be contiguous to 1 or more LICT that are also nominated, and

▪ MFI in the non-LICCT is less than 125% of MFI in LICCT

▪ Maximum nominations in a State could not exceed 25% of total number of LICCTs in the State

▪ Non LICCT Tracts limited to 5% of LICCTs that were also nominated

▪ Rev. Proc. 2018-16 detailed the QOZ designation process for states. The states had until March 21, 2018 to nominate tracts as QOZs (with the ability to request a 30-day extension). The Treasury had to certify designations within 30 days after receiving nominations.

QUALIFIED OPPORTUNITY ZONES – DEFINED (CONT’D)

7

▪ The nomination and designation process is complete, and a full

list of designated QOZs can be found in Notice 2018-48.

▪ The designation of the QOZs remains in effect until the close of

the 10th year after the year of the designation (i.e., December

31, 2028).

▪ A list and a map of the final QOZs can be accessed on the

Treasury’s Community Development Financial Institutions Fund

website here: https://www.cdfifund.gov/pages/opportunity-

zones.aspx.

QUALIFIED OPPORTUNITY ZONES – DEFINED (CONT’D)

https://www.cdfifund.gov/pages/opportunity-zones.aspx

Qualified Opportunity Funds

© 2018 Greenberg Traurig, LLP

• Corporation or Partnership organized for the purpose of investment in Qualified O-Zone Property

• State Law LLC treatment?

• Self-Certification

• 90% Investment Requirement

• Timing Issues

• Examples

• Safe Harbors?

• Measurement of assets?

9

O-Fund Certification


• 1. Qualified O-Zone Business Property

• Tangible Property used in a Trade or Business

• 2. Qualified O-Zone Stock

• Domestic corporation acquired after December 31, 2017 as original issue

• During substantially all of the holding period, the corporation is a Qualified Opportunity Zone Business

• 3. Qualified O-Zone Partnership Interest

• Capital or profits interest in a domestic partnership acquired after December 31, 2017

• During substantially all of the holding period, the partnership is a Qualified Opportunity Zone Business

Qualified O-Zone Property

10


1. Acquired by purchase after December 31, 2017

• Leasehold Interest?

• Related Party Rules

• Structure for Existing Property

2. Use of Property (Original vs. Existing)

3. During substantially all of the holding period, substantially all of the use was in a O-Zone

Qualified O-Zone Business Property

11


• Original use must commence in O-Zone or be subject to substantial improvement

• 30 month basis analysis

• Purpose/Partnership Treatment/Guidance

• Equipment Considerations

• When is property subject to test (original vs. existing use)?

• Exclusion of land in substantial improvement test?

• Restrictions:

• NQFP

• “Sin Businesses”

• Intellectual Property not used in trade or business

• Related Party Transactions

O-Zone Business Property Use Qualification

12


• Substantially all of the tangible property is Qualified O-Zone Property

• At least 50% of total gross income is derived from the activeconduct arising from Qualified O-Zone Property

• Triple net leases?

• Area for additional guidance in relation to acquisition of existing businesses and going concerns

• Discussion of businesses involved in developing intangible property (R&D)

Qualified O-Zone Business

13


• Sale and reinvestment in businesses and property within an O-Fund (churning or recycling of investments)

• Safe harbor for Qualified O-Zone Businesses where tangible property ceases to be O-Zone Business Property for the lesser of 5 years or the date the property is no longer held by the Qualified O-Zone Business

• 15 Year Timeline for Program/5 year Timeline for Investment

• “Substantially All” Test

• Anti-abuse Regulations – Carried Interest

• Basis Rules – Debt Distributions and Treatment of Debt on Sale/Exchange

Additional Considerations

14

Application of

Opportunity Fund Investment


• $200 Equities Sold

• Investment by “taxpayer” – who is the taxpayer?

• $100 Capital Gains

• Discussion of “Gains”

• 1231 Gains/1245 Recapture/Carried Interest?

• Investment in Qualified O-Funds within 180 Days of

liquidation/sale/exchange to third party

Application Scenario

16


• 1031 Recycling

• New limitations on Section 1031 Deferral

• Flexibility/Structuring

• Like-kind Property

• Basis

• 1245 Depreciation Recapture?

• 2026 Tax Event

Differentiation with 1031 Exchanges

17


• 90% O-Fund Investment Threshold

• Qualified Opportunity Zone Property

• Semi-Annual Test

• Safe Harbors?

• Investment Structuring

• Bifurcated Investment

• Discuss Fresh Capital/Non-Gains Treatment

Opportunity Fund Investment

18


• $100 Invested in O-Fund into Qualified O-Zone Property (discussed later)

• Original Use vs. Existing Property

• “Substantial Improvement”

• Tax Basis of $0 – Basis Discussion/Depreciation?

• Immediate Deferral (Example: Liquidation Year 4)

• State Treatment?

Application Scenario – Initial Benefit

19


• Year 5: 10% Step-up in Basis

• Year 7: 5% Step-up in Basis

• December 31, 2026: Recognition Event

• Subject to extension

• Liquidity Issue

Investment Example

20


• 10 Years: Upon sale/exchange of interest in QOF, step-up in basis to Fair Market Value

• Sale of “QOF” interest

• All post-investment appreciation tax free after 10 years

• $100 Investment now worth $600, $500 not subject to capital gains taxation upon disposition

• Depreciation Recapture?

• Debt Distributions/Refinance?

Application Scenario – 10 Year Benefit

21


• Qualified Opportunity Zone Business

• 2 Tier Structuring

• Discussion of relocation/start-up activity

• Existing Operating Businesses in an O-Zone

• 2026 Benefit Discussion

• Appreciation on Portfolio Companies

• Twinning with Real Estate

Operating Companies and Equipment

22


• 1031

• Family Offices

• High Net Worth Individuals

• Private Equity

• Venture Capital

• Real Estate/Specialty Funds

• Hedge Funds*

Types of Investors

23


• 10 Year Opportunity Zone Designation

• December 31, 2019

• December 31, 2021

• December 31, 2024?

• December 31, 2026?

• 5 Year Grace Period for QOZBs

• Creating Advancement and Personal Improvement in Targeted American Localities Act (CAPITAL – H.R. 6890)

Phase Down

24

25

▪ The benefits of the OZ program may be combined with other tax subsidy programs such as those provided for renewable energy. Details on how these programs may be combined is expected to be addressed in the upcoming Treasury Regulations.

▪ There are two federal incentives for investments in renewable energy are the Section 45 Production Tax Credit and the Section 48 Energy Credit. Importantly, these options are alternatives and cannot be used in conjunction with each other (i.e., a project cannot claim both the Production Tax Credit and Energy Credit).

▪ Wind are eligible for the Section 48 Production Tax Credit or may elect to take the Section 48 Energy Credit. For all other technologies, the credit is not available for systems whose construction commenced after December 31, 2017.

▪ Solar, fuel cell, small wind projects and certain other types of power production are eligible for the Section 48 Energy Credit.

RENEWABLE ENERGY TAX INCENTIVES

26

▪ As its name suggests, the Production Tax Credit (“PTC”) is based off of the facility’s electrical output over a period of time.

▪ General. The PTC is based on the electricity output from renewable energy sources, including wind power. The electricity must be sold by the taxpayer to an unrelated person and must be produced in the United States or a U.S. possession.

▪ Carryback/Carryforward. Unused PTCs can be carried back to the preceding tax year or carried forward to each of the next twenty tax years.

SECTION 45 PRODUCTION TAX CREDIT (CONT’D)

27

▪ Energy Credit in Lieu of the PTC. Taxpayers have the option of taking Section 48 Energy Credits in lieu of the PTC. This option is discussed in greater detail on subsequent slides.

▪ Value of the PTCs. The calculation of the value of the PTCsgenerated by qualifying wind facilities is determined by the date on which such facility begins construction. The PTC is currently equal to 2.4 cents per kilowatt hour of electricity produced each year over a 10 year period beginning on the date the wind facility is placed in service. If a wind facility begins construction before January 1, 2017, it is eligible for 100% of the PTCs it generates.


28

▪ If a wind facility begins construction on or after January 1, 2017, the PTCs for wind facilities are phased out by 20% per year until they are completely phased out for projects that begin construction after December 31, 2019.

▪ There are two alternative tests to determine if the “beginning of construction” requirement has been met: (1) by making a significant beginning of physical work, or (2) by incurring or paying at least 5% of the total cost of the facility. Both tests have a continuity requirement where continuous progress must be made toward completing the project after construction begins.

▪ The continuity requirement will be deemed met if an energy property is placed in service no more than four calendar years after the calendar year during which construction began.


29

▪ General. The Energy Credit is part of the U.S. investment tax credit (“ITC”) and the calculation of the amount of the ITCs for energy property is determined by the date on which such facility begins construction.

▪ If a solar facility begins construction before December 31, 2019, it is eligible to use an energy percentage of 30% to determine ITCs. If a solar facility begins construction after December 31, 2019, but before January 1, 2021, it is eligible to use a reduced energy percentage of 26% to determine ITCs. If a solar facility begins construction after December 31, 2020, but before January 1, 2022, it is eligible to use a further reduced energy percentage of 22% to determine ITCs. If construction begins in 2022 or later, the ITC is decreased to 10% for non-residential solar projects that begin construction before January 1, 2022, and are placed in service after December 31, 2023, but drops to 0% for residential solar projects.

▪ Similar to the PTC, the ITC has a continuity requirement which will be deemed met if an energy property is placed in service no more than four calendar years after the calendar year during which construction began.

SECTION 48 ENERGY CREDIT

30

SECTION 48 ENERGY CREDIT (KEY DATES)

31

▪ Carryback/Carryforward. Unused ITCs can be carried back to the preceding tax year or carried forward to each of the next twenty tax years.

▪ Recapture Period. While the full ITC is available in the year that the Energy Property is placed in service, the ITC actually vests over a 5 year period and is subject to recapture if the underlying property is disposed of by the taxpayer or ceases to be Energy Property within such five year period. For example, if the Energy Property is disposed of by the taxpayer within two years of being placed in service, 80% of the ITC would be recaptured.

▪ Generally, foreign investment in U.S. renewable projects requires a U.S. tax base or a U.S.-based tax equity investor. Since it is possible to carry forward the tax benefits, even if no U.S. tax equity investor is utilized, future taxable income generated by the project may be offset by tax credits and losses that are carried forward. Possible structures for foreign investment will be discussed on later slides.

SECTION 48 ENERGY CREDIT (CONT’D)

32

▪ Code Section 48(a)(5). For purposes of taking the ITC in lieu of the PTC, the term “Energy Property” means any property at a qualified facility within the meaning of Code Section 45 which is:

▪ Tangible personal property; or

▪ Other tangible personal property (not including a building or its structural components), but only if such property is used as an integral part of the qualified facility; and

▪ with respect to which depreciation is allowed.

▪ For property that generates electricity, qualifying energy property includes storage devices, power conditioning equipment, transfer equipment and parts related to the functioning of those items. However, energy property does not include any electrical transmission equipment, such as transmission lines and towers, or any equipment beyond the electrical transmission stage, such as transformers and distribution lines.


33

▪ Energy Property is generally depreciable over five years on an accelerated basis. However, changes in 2018 tax reform permit the immediate expensing of Energy Property in the year in which the property is commissioned.

▪ The tax depreciable basis that the taxpayer claims for the Energy Property must be reduced by 50% of the amount of the Energy Credit.

▪ For example, if a 30% credit is claimed on certain Energy Property that costs $100,000, then the taxpayer is entitled to a $30,000 Energy Credit ($100,000 * 30%). The taxpayer will have a depreciable basis in the Energy Property of $85,000 (equal to the cost of the equipment ($100,000) less $15,000 (or 50% of the $30,000 Energy Credit)).


34

▪ The Energy Credit is not allowed with respect to property used outside the United States or outside U.S. possessions.

▪ The Energy Credit is not allowed with respect to property owned by or leased to:

▪ Tax-exempt organizations;

▪ Governmental units; or

▪ A foreign person or entity.

▪ However, a foreign person or entity may be eligible if more than 50% of the gross income derived by the foreign person or entity from the use of the Energy Property is: (i) subject to U.S. income taxation; or (ii) included in the gross income of a U.S. shareholder under Code Section 951.

▪ Moreover, as will be discussed later, structuring options are available through the use of U.S. “blocker” corporations which allow ineligible persons or entities to participate in a project’s ownership.


34

Structures

and Opportunities


• 2026 Fair Market Value

• Inside/Outside Debt – Margin Debt

• Carried Interest and Promote?

• JV Structuring

• Preferred Returns – Accrual and Options

• A & B Companies

• Substantial Improvement Structures?

Advanced Strategies

36


• Limited Partnerships/Preferred Interests

• Project Finance

• Return Targets for Investors

• Options/Exits

• Replacement of Debt and Enhancement of Equity

• O-Fund Equity invested with Non O-Fund Equity

• Warehousing

Structuring

37

Strategies for Today


• 1031 vs. Opportunity Fund

• Pending Acquisition

• Trailing Sale

• Captive Funds

• Single Asset vs. Pooled Funds

• Fund Formation

Strategies

39


• Churning/Recycling?

• Eligible Taxpayers?

• Safe Harbors for Initial Investment/Construction or Treatment of Construction Disbursement Account as Reasonable Working Capital?

• Disposition

• Active Conduct

• Gains?

• LLC Treatment

• Substantially All?

• Substantial Improvement and Partnership Treatment

• Sale or Exchange within a Partnership

• Basis Treatment/Depreciation/Recapture

• Debt at disposition

• Timelines

• Non Pro-Rata Distributions (Carried Interest)

• Debt Distribution vs. Redemption (Sale or Exchange Treatment?)

• Acquisition of Property Prior to December 31, 2017 and Operating Businesses

• Reasonable Expectations for Active Conduct and Trade or Business?

Potential Regulatory Guidance

40

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41

INVESTMENT STRUCTURES:

DIRECT INVESTMENT IN PARTNERSHIP OR

LIMITED LIABILITY COMPANY WITH US PARTIES

Power Purchase Agreements (PPAs)(Building Owners/Tenants Commit to Purchase Energy Output)

Payment Power

Tax Credit

EquityTax

Credits

Operates

Project

Incentive Programs(RECs/Carbon

Credits/Rebates)

DIRECT OWNERSHIP STRUCTURE DIAGRAM

Development Contract

Debt

P&IOwner LLC (QOF) Lender

Investor LP

Manager

Facility Developer


42

FOREIGN INVESTMENT STRUCTURE WITH

U.S. “BLOCKER” CORPORATION


Payment Power

Tax Credit

EquityTax

Credits

Operates

Project/Investor


Credits/Rebates)


Debt

P&IOwner LLC (QOF) Lender

Investor LP

US Blocker Corporation

Facility Developer

Foreign Person/Entity


43

INVESTMENT STRUCTURES: DIRECT

INVESTMENT IN US PARTNERSHIP OR

LIMITED LIABILITY COMPANY

▪ An owner/developer may partner with an equity investor that has both qualifying Section 1400Z-2 gain and an appetite for tax credits.

▪ In such case, the Energy Property is generally owned by a US partnership or limited liability company (each a flow-through entity for US income tax purposes) with the equity investor making a capital contribution to the partnership or limited liability company based on the amount of ITCsexpected to be generated.

▪ The partnership or limited liability company may also obtain traditional non-recourse permanent financing in addition to the equity investor’s capital contributions.

▪ Pursuant to the transaction documents, certain management, development and other fees may be paid to the owner/developer.


44



LIMITED LIABILITY COMPANY (CONT’D)

▪ The owner/developer typically has an option to purchase the equity investor’s interest in the partnership or limited liability company after the expiration of the five year recapture period (if the ITC is elected in lieu of the PTC). The option purchase price is typically equal to either the fair market value of the equity investor’s interest or an amount sufficient to achieve a targeted investor internal rate of return. The tax credit investor will typically also have a put option in the event that the purchase option is not exercised by the owner/developer.

▪ For PTC investments, a put call arrangement is generally put in place so that the investors no longer participate in the project after the 10th year.

▪ Combined with the Section 1400Z-2 fair market value election that the investor can make this may provide a unique opportunity to eliminate much of the original gain that was deferred, especially in a partnership flip structure, because there is generally not much value to the investor’s interest when it exits an ITC or PTC QOF. Note that the OZ program benefit would not available to the investors, but for investors who were already looking at projects in OZ areas this provides an additional tax benefit as compared to a non-OZ investment.


45



LIMITED LIABILITY COMPANY (CONT’D)

▪ This structure is available for projects involving PTCs or ITCs.

▪ The owner/developer and the equity investor will share in the tax allocations and cash distributions that are made by the partnership or limited liability company.

▪ Generally, these tax allocations and cash distributions are made 99% to the equity investor and the remaining 1% or less to the owner/developer until specific date or until the equity investor has reached a targeted internal rate of return.

▪ Thereafter, the partnership or operating agreement may provide for a “flip” of the tax allocations and cash distributions so that the owner/developer participates at a higher percentage in these items.

▪ The flip generally occurs after year five with the ITC or recapture period, or after year ten in the case of PTC projects.


46


LEASE PASS-THROUGH STRUCTURE


Payment Power

Tax Credit

Equity

Tax

Credits

Operates

Project

Rent

Lease


Credits/Rebates)

LEASE OWNERSHIP STRUCTURE DIAGRAM

IRC§50(d)(5)

Tax Credit

Pass-Through


Debt

P&I

Owner Manager LLC Owner LLC (QOF) Lender

Tenant LLC

Tenant Manager LLCInvestor LP

Facility Developer

Retains balance of losses

Less than 50%

ownership

Less than

50% of

losses

QOF Equity

Investor LP


47



▪ Only available for projects involving ITCs.

▪ In cases where the tax credit investor is interested less in the depreciation deductions generated by the project, the Lease Pass-Through Structure allows for the bifurcation of the ITCs and the depreciation deductions because of the lease pass-through election.

▪ The transaction can be structured so that the lessee is entitled to the ITCs and the lessor is entitled to the depreciation deductions.

▪ The rent payments associated with the lease are designed to flush most, but not all, of the cash flow out of the lessee.


48



(CONT’D)

▪ Requirements of the pass-through election by the lessor:

▪ The property must be “Section 38 Property” (the property cannot be a building or structural component of a building);

▪ The original use of such property must commence with the lessor;

▪ The lessee must be the first person to actually use the property for its intended function;

▪ A statement of election to treat the lessee as a purchaser must be made (See Treasury Regulation 1.48-4); and

▪ The lessor cannot be a mutual savings bank, cooperative bank, a domestic building and loan association, a regulated investment company or a real estate investment trust.


49



(CONT’D)

▪ This structure also permits the QOF investors to be bifurcated from the tax equity investors which could allow the QOF investors to share in the upside of the project, if any, upon disposition.

▪ Query whether the transaction can be structured so that a QOF with the tax equity investor acquires the partnership interest of the Tenant LLC and the Tenant LLC’s activities qualify as a QOZ business which would permit the tax equity investor to also receive the tax benefits of the OZ program in addition to the ITCs.


50


SALE/LEASEBACK STRUCTURE


Payment Power

Tax Credit

Equity

Tax Credits &

Depreciation

Operates

Project

Sells

Project

Leases

back


Credits/Rebates)

SALE/LEASEBACK OWNERSHIP STRUCTURE DIAGRAM


Debt

P&I

Owner Manager LLC Owner LLC (QOF) Lender

Tenant LLC

Tenant Manager LLC

Investor LPFacility

Developer

Rent


51


SALE/LEASEBACK STRUCTURE

▪ Only available for projects involving ITCs.

▪ Renewable energy developer constructs project, then sells the project to institutional

investor which then leases the project back to the developer.

▪ An investor in a sale/leaseback transaction for projects involving ITCs has up to 3

months following the date on which the project is commissioned to acquire the project

and still be eligible for the ITC.

▪ Developer that wants to retain project must purchase at the end of the tax benefits

period for the fair market value of the project (unlike a project structured using a

partnership “flip” where the developer retains most of the residual value).


52


SALE/LEASEBACK STRUCTURE (CONT’D)

▪ The lessor/owner generates a large after-tax yield with this structure because it

retains the residual value.

▪ This structure permits a tax equity investor to participate in the QOF and receive the

benefit of both the tax deferral on the invested gain, as well as, the appreciation in the

project not being subject to tax.


53


LEASE STRUCTURES

IRS Rev. Proc. 2001-28 provides the following guidelines which must be met for the Service to issue an

advance ruling indicating that a lease will be respected as a lease, rather than a sale, for tax purposes:

▪ The lessor has made a minimum unconditional “at risk” investment of at least 20% of the cost of the

property throughout the lease term.

▪ Neither the lessee nor any member of its affiliated group has a contractual right to purchase the property

from the lessor at a price that is less than its fair market value at the time the right is exercised.

▪ The lessee and its affiliates (which might include the lessor if the lessee owns a 50% or greater interest in

the lessor) have not furnished any part of the cost of the property or the improvements or additions (except for

the specified nonseverable improvements and improvements or additions owned by the lessee that can be

readily removed without causing material damage to the leased property).

▪ Neither the lessee nor its affiliates may lend any of the funds necessary to acquire the property or

guarantee any indebtedness created in connection with its acquisition.

▪ The lessor must expect to receive a profit from the transaction apart from the value of, or the benefits

derived from, the tax deductions and other tax attributes that arise from the transaction.


54


LEASE STRUCTURES (CONT’D)

▪ The advance ruling guidelines identified in Rev. Proc. 2001-28 are

stricter than the standards adopted by the courts for identifying the

tax owner of property.

▪ “Benefits and Burdens” Analysis: In general, the traditional court

analysis focuses on the form of the transaction and whether the

purported owner would benefit from any increase in the value of the

property or bear the burden of a loss of capital.

James O. Lang

813.318.5731

[email protected]

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Qualified Opportunity Zones & Energy Projects: New Tax Incentivesmedia.straffordpub.com/products/qualified-opportunity... · 2018-10-17 · There are two federal incentives for investments