QOF Ground-Up Development Racing the Working Capital Safe Harbor
A Qualified Opportunity Fund has deployed capital into a QOZB for ground-up construction and needs the loan closed and drawing inside the 31-month working capital safe harbor so the fund's asset test is not jeopardized. We size construction debt around the QOF's equity contribution and coordinate closing directly with the fund's tax counsel, so the loan itself is never the reason the safe harbor is missed.