Property
(17) Property(i) In general. The term property means money, securities, or any other property. (ii) Inclusion events regarding QOF corporation distributions. For purposes of 1.1400Z2(b)-1(c), in the context in which a QOF corporation makes a distribution, the term property does not include stock (or rights to acquire stock) in the QOF corporation that makes the distribution. (18) QOF. The term QOF means a qualified opportunity fund, as defined in section 1400Z-2(d)(1) and 1.1400Z2(d)-1. (19) QOF C corporation. The term QOF C corporation means a QOF corporation other than a QOF S corporation. (20) QOF corporation. The term QOF corporation means a QOF that is classified as a corporation for Federal income tax purposes. (21) QOF RIC. The term QOF RIC means a QOF that elects to be taxed as a RIC for Federal income tax purposes. For purposes of section 1400Z-2 and the section 1400Z-2 regulations, a RIC is a regulated investment company within the meaning of section 851. (22) QOF REIT. The term QOF REIT means a QOF that elects to be taxed as a REIT for Federal income tax purposes. For purposes of section 1400Z-2 and the section 1400Z-2 regulations, a REIT is a real estate investment trust within the meaning of section 856. (23) QOF owner. The term QOF owner means a QOF shareholder or a QOF partner. (24) QOF partner. The term QOF partner means a person that directly owns a qualifying investment in a QOF partnership or a person that owns such a qualifying investment through equity interests solely in one or more partnerships. (25) QOF partnership. The term QOF partnership means a QOF that is classified as a partnership for Federal income tax purposes. (26) QOF S corporation. The term QOF S corporation means a QOF corporation that has elected under section 1362 to be an S corporation. (27) QOF shareholder. The term QOF shareholder means a person that directly owns a qualifying investment in a QOF corporation. (28) QOZ designation notice. The term QOZ designation notice means a notice designating population census tracts as qualified opportunity zones (QOZs) in guidance published in the Internal Revenue Bulletin (see 601.601(d)(2) of this chapter). (29) Qualified opportunity zone business. The term qualified opportunity zone business has the meaning provided in section 1400Z-2(d)(3) and 1.1400Z2(d)-1(d). (30) Qualified opportunity zone business property. The term qualified opportunity zone business property has the meaning provided in section 1400Z-2(d)(2)(D) and 1.1400Z2(d)-2. (31) Qualified opportunity zone partnership interest. The term qualified opportunity zone partnership interest has the meaning provided in section 1400Z-2(d)(2)(C) and 1.1400Z2(d)-1(c)(3). (32) Qualified opportunity zone property. The term qualified opportunity zone property has the meaning provided in section 1400Z-2(d)(2)(A) and 1.1400Z2(d)-1(c)(1). (33) Qualified opportunity zone stock. The term qualified opportunity zone stock has the meaning provided in section 1400Z-2(d)(2)(B) and 1.1400Z2(d)-1(c)(2). (34) Qualifying investment. The term qualifying investment means an eligible interest, or portion thereof, in a QOF to the extent that a deferral election is made and applies with respect to such eligible interest or portion thereof and the IRS has been timely notified of the deferral election. An eligible interest in a QOF ceases to be a qualifying investment of the owner upon, and to the extent of, the occurrence of an inclusion event with regard to that eligible interest, or portion thereof, except as is expressly provided otherwise in 1.1400Z2(b)-1(c) or other provisions of the section 1400Z-2 regulations. (35) Qualifying QOF partnership interest. The term qualifying QOF partnership interest means a direct or indirect interest in a QOF partnership that is a qualifying investment. (36) Qualifying QOF stock. The term qualifying QOF stock means stock in a QOF corporation that is a qualifying investment. (37) Qualifying section 355 transaction. The term qualifying section 355 transaction means a distribution described in 1.1400Z2(b)-1(c)(11)(i)(B). (38) Qualifying section 381 transaction. The term qualifying section 381 transaction means a transaction described in section 381(a)(2), except the following transactions: (i) An acquisition of assets of a QOF by a QOF shareholder that holds a qualifying investment in the QOF; (ii) An acquisition of assets of a QOF by a tax-exempt entity as defined in 1.337(d)-4(c)(2); (iii) An acquisition of assets of a QOF by an entity operating on a cooperative basis within the meaning of section 1381; (iv) An acquisition by a QOF of assets of a QOF shareholder that holds a qualifying investment in the QOF; (v) A reorganization of a QOF in a transaction that qualifies under section 368(a)(1)(G); (vi) A transaction, immediately after which one QOF owns an investment in another QOF; and (vii) A triangular reorganization of a QOF within the meaning of 1.358-6(b)(2)(i), (ii), or (iii). (39) Related persons. The term related when used with regard to persons and the term related persons means that there is a relationship described in section 267(b) or 707(b)(1), determined by substituting 20 percent for 50 percent each place it occurs in such sections. The term unrelated when used with regard to persons means that there is no relationship described in preceding sentence. (40) Remaining deferred gain. With respect to a qualifying investment, the term remaining deferred gain means the full amount of gain that was deferred under section 1400Z-2(a)(1)(A), reduced by the amount of gain previously included under 1.1400Z2(b)-1(b). After December 31, 2026, an eligible taxpayer's remaining deferred gain is $0. (41) Section 1400Z-2 regulations. The term section 1400Z-2 regulations means the regulations in this chapter, which are prescribed in whole or in part under section 1400Z-2.