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⚡IMPACT LEVEL 3 — NOTEWORTHY

Epstein File EFTA01374664: Mehmet Oz, Oz and Memorandum (DS10)

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Tax document summarizing Opportunity Zone (OZ) tax benefits enacted in late 2017 as part of the Tax Cuts and Jobs Act, describing three tax benefits: Temporary Deferral, Basis Step-Up, and Ten-Year Benefit. The document addresses tax treatment of funds as Qualified Opportunity Funds.

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This summary only addresses tax issues specific to the treatment of a fund as a QOF and/or tax benefits under the Opportunity Zone ("**OZ**") rules, and does
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Tax benefits under the **OZ** rules The **OZ** rules were enacted in late 2017 as part of the Tax Cuts and Jobs Act.
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The **OZ** rules provide three tax benefits: (1) Temporary Deferral, (2) Basis Step-Up, and (3) Ten-Year Benefit. 1. Temporary Deferral.

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