The 2017 tax bill provides massive tax benefits to any taxpayer that recognizes capital gain (“Gain”) and that invests an amount equal to the Gain to acquire an interest (“Fund Interest”) in an “Opportunity Zone Fund” (a “Fund”) which in turn invests in certain low-income areas designated by each state (“Zones”). The benefits of investing Gain in a Fund are as follows:

..Tax on the Gain is deferred (“Deferred Gain”) until the earlier of (i) when the Fund Interest is sold or (ii) December 31, 2026, even if the taxpayer takes out a loan against the Fund Interest.

..When the Deferred Gain is finally recognized, the amount recognized is the lesser of (i) the amount of the Deferred Gain or (b) the value of the Fund Interest at that time. The character of the Deferred Gain when ultimately recognized is the same as in the year of the original sale...