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What methods do the new regulations provide for gross sourcing revenue for a QOZB?

Since 50% of the gross receipts of a QOZB must be attributable to income from an active business within a QOZ, what are my options to calculate that?


Answers
  • Matthew Rappaport
    October 10, 2019

    You have four: three safe harbors and facts-and-circumstances analysis. The safe harbors are pretty reasonable and should be achievable for most businesses that are not trying to use the QOZ program abusively.

  • Maria De Los Angeles Rivera
    October 11, 2019

    The second set of regulations provides three alternative tests and a facts and circumstances test. The three tests are: 50% of the services measured by hours are rendered from a zone; 50% of the services measured in money is rendered from a zone; and 50% of gross income is generated by management and tangible property located in the zone.

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