Future Opportunity Zone Reform, With Mike Novogradac And John Sciarretti

What tax policy changes may unfold soon, and how might Opportunity Zones be reformed later this year or in 2022?

Mike Novogradac is the managing partner of Novogradac, a top 50 accounting firm founded in 1989. John Sciarretti is chair of the Novogradac Opportunity Zones conferences and leader of the Novogradac Opportunity Zones Working Group.

Click the play button above to listen to my conversation with Mike and John.

Episode Highlights

  • A summary of the current legislative landscape, including the ramifications of the narrow Democratic majorities in Congress.
  • The likelihood of changes to the Opportunity Zone program, including the phasing out of higher income tracts and extension of the investment deadline from 2026 to 2028.
  • How changes in capital gains rates and individual income tax rates could impact the Opportunity Zone program.
  • The need for enhanced reporting requirements relating to Opportunity Zones, and the possible timeline for such a modification.
  • What the end of COVID relief measures means for Opportunity Zone funds and investors.
  • A deep dive into working capital requirements, including extensions currently in place.
  • Trends in Opportunity Zone equity investments, including a breakdown among real estate types and an uptick in cash flowing to operating businesses.
  • An overview of the upcoming Opportunity Zones conference in Cleveland in November 2021.

Featured on This Episode

Industry Spotlight: Novogradac


Based in San Francisco, Novogradac is a top 50 national accounting firm with an emphasis in the real estate sector, specializing in tax credits. In recent years, the firm has become one of the foremost thought leaders in the Opportunity Zone industry and are one of the leading providers of education and live events in the space.

Learn More About Novogradac:

About the Opportunity Zones Podcast

Hosted by OpportunityDb.com founder Jimmy Atkinson, the Opportunity Zones Podcast features guest interviews from fund managers, advisors, policymakers, tax professionals, and other foremost experts in opportunity zones.

Show Transcript

Jimmy: Welcome to the “Opportunity Zones Podcast.” I’m your host, Jimmy Atkinson. And joining me once again today, are partners at Novogradac, a national professional services firm with deep expertise in Opportunity Zones. Mike Novogradac joins us from San Francisco. And John Sciarretti is calling in today from Dover, Ohio. Gentlemen, welcome back to the podcast.

Mike: Thank you. Happy to be back.

John: Thank you. Great to be here.

Jimmy: Great to have you both back with me. It’s been a while since I spoke with the two of you the last time the two of you were on this podcast was late October of 2020. I think about a week before election day. And at that time, we weren’t sure if we…another four years of President Trump or a new administration under President Biden. We weren’t sure what the balance of power would wind up being in Congress. A lot has transpired since we last spoke. Now we know Biden’s our president newsflash, he’s been our new president for about eight months or so now. And we have a democrat controlled house and Senate regarding tax policy. And in particular Opportunity Zones, of course, what has transpired so far under this administration, and this new session of Congress, and what do you anticipate will unfold in the coming months?

Mike: Great, thank you, Jimmy. And yes, that is quite the newsflash Joe Biden won the election and the Senate and the House are controlled by the… However, they have the narrowest of control in both the House and the Senate. And I say narrowest of control in that in the Senate, the Democrats have 50 senators, and there’s 50 Republican senators, and they have control by virtue of the vice president being a Democrat, Kamala Harris. So that’s significant, because when you have that limited control, it limits what you can do as the controlling party. And then in the house, which was a little bit of a surprise in the election results, the democrats only have a few seat majority in the House. And the significance of both of those, is that in order to get a tax bill passed, that the democrats would like to pass, they will have to do it through this concept called budget reconciliation. And budget reconciliation basically means you can pass a tax bill with 50 votes in the Senate.

Normally, you need 60 votes to avoid closure. I won’t get in all the details or the listeners. But the key is there’s efforts by the Democrats to pass a democrat only infrastructure plan or bill back better plan. And there’s…it’s unclear as to how much this plan will be in terms of total spending between tax cuts or tax increases in tax spending, along with the direct spending, it’s going to be somewhere between maybe 2 trillion to three and a half, three and a half trillion is what the house is working on right now. The thought is the Senate won’t be able to pass something at that larger level, it’d be less than that may be 2 trillion, or 2.2 trillion. And the significance of there only being 50 Democrats in the Senate is that every democratic senator can stop the senate from moving forward. And right now the Senates negotiating where it is they wanna be in terms of the size of this coming bill.

So we’re right now we’re waiting to see what that bill will be the significant news with respect Opportunity Zones is that in this process to pass a reconciliation bill, the House Ways and Means Committee has passed a tax bill out of that will then go as part of a larger bill to the House floor. And we’re unclear when that’s all gonna happen. It could happen by middle of October, it could maybe not happen until just before December 25th. It could not happen till early next year, and it could not happen at all. So we’re sort of waiting to see what happens there. But for those that are…and to focus on Opportunity Zones, we have within our Opportunity Zones working group and others have been looking for some changes to the Opportunity Zones statute. We’d like to be able to have Fund-to-fund concept work within Opportunity Zones that you really can’t do right now. But there is a desire by many to phase out some of the higher income tracks that were designated by governors which they had the right to do, but there’s a concern at some a handful maybe 100, 150, high-end contracts should be phased out. There’s also an effort by many to extend the investment deadline from 2026 to 2028.

So there are a number of policy initiatives that we’d like to see move forward. Unfortunately, none of those policy positions made its way into the House Ways and Means so that there isn’t any direct effect on opportunity zones in the House Ways and Means Bill. And right now, we’re not really expecting anything in the Senate either. But that remains to be seen.

There is though, a pretty significant indirect effects coming out of the House Ways and Means Bill, and that is that the House Ways and Means Bill would increase the corporate tax rate from 21% to 26.5%. And would increase the top tax rate for individuals, the ordinary income rates would go from 37% to 39.6%, and the capital gains rate, would go up to 25%, plus the net investment income tax of 3.8%. So basically 28.8%, and for incomes in excess of 5 million, the tax rate would go up an additional 3%. So you could get up to a 31.8% capital gains rate for individuals. So there’s possibility of the rates to go up for Opportunity Zones is obviously, going into the future, once this new regime is in place, if it hasn’t acted, then Opportunity Zones become a little bit more valuable. Because your Opportunity Zones are all about deferring gain, and then avoiding gain being excluded gain on your appreciation of your investment. And if the tax rates and the capital gains are higher than the value of that exclusion is higher.

But I will say and the question that we’ve been getting from clients through all of this is, “What if I have capital gains this year?” And we’ve talked about this before? I know, Jimmy, that if you have capital gains this year in 2021, then the tax rate is 20%, or 23.8%, does it really make sense to defer that gain out until 2026, because you’re deferring it to potentially a higher tax rate environment. And we’ve run lots of calculations for our Opportunity Zones, working group members. And it’s pretty clear that for real estate investments, which in most Opportunity Zones investments are so far, that the benefit is still of investing outweighs…that the fact that you’re paying a higher tax rate in 2026 is offset by all the other benefits of Opportunity Zone investing. And you still generate a pretty substantial positive after tax rate of yield rate of return of maybe 300 or 500 basis points higher by investing in Opportunity Zones and comparable areas. But we’re running those numbers for a lot of clients. And every case needs to be looked at individually. But it’s still very beneficial to be investing this year, even if the capital gains rates go up.

Jimmy: Yeah, and at the end of the day, like you mentioned, if capital gains rates go up, it makes the exclusion benefit all that much more valuable. Were you surprised that the House Ways and Means Bill only increased the capital gains rate from 20% to 25%? Were you expecting higher or did that come in about where you were expecting it to?

Mike: Oh, it came in about where I was expecting it to I was sort of projecting it to be 25% to 28%. And with the net investment income tax is 28.8% and without it is 25%. So I’m like, “I’m right in a wheelhouse.”

Jimmy: You hit it, then. I think some people were expecting it to possibly go all the way up to the ordinary income tax rate, though.

Mike: Well, that’s what Biden proposed. President Biden did propose taking it up to 39.6% for really high income levels. But once again, you have to look at the Senate. And on the Senate side. Senator Joe Manchin from West Virginia had said that he could see an increase in capital gains tax rate, but he thought 39.6% was too high. So based upon what he’s willing to accept in the Senate, I think modified what the house was willing to pass.

Jimmy: Gotcha, that makes sense. Going back to those Opportunity Zones Working Group initiatives that you’re working on through your Novogradac Opportunity Zones Working Group, fund-to-funds concept, phasing out higher income tracks, extending the investment deadline to 2028 understood that none of those made it into this bill we’re discussing now. But when do you anticipate that maybe some of those ideas will gain a little bit of traction, or is that anybody’s best guess? Do you have any insight into when those may come into play?

Mike: I wish I did. And I omitted probably the number one request and that’s reporting. We need to get reporting for Opportunity Zones. And the way in which it was enacted the Opportunity Zones statute was originally enacted, caused those reporting requirements to have to be excluded. And unfortunately, we can’t include them in this bill, because the same reason why if reporting had to be excluded in 2017 would apply in this tax bill. But your question about when do I think we could see some action in some of these tax provisions, it’s hard to say. It’s really hard to say because it’ll take a tax bill, And once we kind of make its way through this tax bill, and it could be that the Senate put something in there. But I’m not saying it’s not gonna happen. But we’re not getting any indication just yet that that’s gonna happen. Then after that, we have to wait and see when will the next major tax bill the or even minor tax bill, and it’s too hard to predict right now, because so much attention is getting placed right now on the fact that the government budget is expiring. And yet at the end of this month, they have to do some type of continuous resolution, that you have the other infrastructure bill that was already passed in the Senate, the house was supposed to vote on next week. And then we have the debt ceiling limit, then we have this 2 to $3.5 billion bill back better plan. So all of that, and we’re saying, “Well, what’s gonna happen after that?”

Jimmy: But it may be a little ways down still Opportunity Zones, not super high on the priority list at this point for Congress, it seems?

Mike: That’s correct.

Jimmy: John, I wanna bring you in now turning to you passed us a series of Coronavirus relief measures in 2020, mostly and then early on in 2021, as well, what’s the current state of COVID relief? Where do all those relief measures stand?

John: Well, the relief measures are coming to an end, even though unfortunately, it’s not like COVID is coming to an end. But in those relief measures, the 180 day extension that’s already passed. So that was March 31st, gave folks time to March 31st to invest even though it was beyond their 180 day period. So that’s ended. And another provision was around the substantial improvement test where you actually had extra time, there’s 30 months in order to substantially improve an asset that’s already used with respect to real estate, let’s say, and you had this additional time, where you could ignore the period from April of 2020 to March 2021.

So if you happen to be…if that time period have to be in the period of your substantial improvement, then that helps folks gives them a little more time to improve their property. And the 90% test is still in effect through the end of this year, the way that worked is that if the first or last testing date, so the first six months of last or the end of the year testing day landed between April 20th, or April 2020, and June 2021, then even if you happen to fail the 90% test, the penalties were waived for that whole tax year. And so we found yourself in 21, because that period, that testing date ends in June, the first testing date of this year for our calendar year, clause, would be June 30th 2021. If they happen to have a penalty because they failed the test, then that penalty for 2021 would be waived.

And the interesting thing about that test is that it’s not as broad as it appears to be. So your investment holding period 90% of the time that you hold that qualified business, it has to be qualified. And so if in fact you failed the 90% test, because you had a bad business, a bad QOZB, even though you may be able to have your penalty waived for 2021, say that test is cumulative. And so 90% of the holding period, it has to be good. And so if it was bad for one year, then in the next year, if you happen to cure that failed QOZB and let’s say you held the investment for two years, you would only be at 50%, like 50% of your holding period would be good. And so that lives with you through the end of your investment. So even though your penalties may have been waived, you could end up with penalties later in your investment period, because you didn’t meet this cumulative test.

And I think that a lot of folks miss that, Jimmy that they feel like sort of anything goes during this waiver period. And as long as they get things back in line when it’s over at the end of 21, then they’ll be okay going forward. But this cumulative test is an issue that folks need to think about. So that’s an important aspect. But that is still out there until the end of this year. The Working Capital Safe Harbor, there was some relief around that. And that’s still very much in play. The belief was that if your project or business was in a fairly declared disaster area, which is the whole country during this COVID phase, and then by regulations, you can have up to or not more than is the actual language an additional 24 months to in your Working Capital Safe Harbor.

And so if you have working capital assets and you have working capital safe harbor period, the general rule is you have 31 months to have a qualified business, meaning that your assets are used in an Opportunity Zone a qualified Opportunity Zones business. And your assets will sort of meet the 70% test where they’re being used in an Opportunity Zone that Working Capital Safe Harbor that 31 month period. And the general rule is you can have two 31 month periods, or you can have many 31 month periods depending on when you receive your working capital assets. But you have a maximum of 62 months, there’s an additional 24 months that was tacked on to that period. And so that is still, like I said, very much in play, as long as you’re in the Working Capital Safe Harbor before June 30th, 2021. So that’s something that I think many folks have taken advantage of a little giving them a little more time to start up their business or construct any sort of real estate in that Opportunity Zone.

Jimmy: So a little more time, I would say I would actually say a lot more time, right? I mean, you could, in theory, get up to 84 months or seven years. Is that right? In some cases?

John: That’s correct.

Jimmy: I know that there’s been some changes to the Working Capital Safe Harbor, there’s some proposed regulations and some correcting amendments that were released relatively recently. What’s the update there? What changes have been made or are proposed?

John: Well, there’s the proposed Regs and a comment period now or the comment periods over but they haven’t been finalized yet, with respect to the Working Capital Safe Harbor, they did clarify that, when you look at the Working Capital Safe Harbor, there’s sort of three prongs to the test, you have to have working capital assets that you designate to use to construct Opportunity Zone property. And then you have to have this sort of plan of how you’re going to use those assets over that 31 month period, or longer if you happen to have more than one 31 month period, or an extension. And then the last prong of that test requires that you carry out that plan, that how you carry out that plan is substantially consistent with how you described your plans.

So because of COVID. And because of the federally declared disaster areas, there’s a provision, they provide a provision that if you have to change your plan, meaning that you wouldn’t be substantially consistent with your plan, then as long as you adopt a new plan, within 120 days of the close of the incident period. So the incident period is this sort of fairly declared disaster period, which, like I said, right now, we’re not at the end of it yet. But once we do come to the end of it, God willing, very soon, you would have 120 days after the close of that period, to change your plan, and you could still be considered substantially consistent because you would adopt this new plan, and then you just have to stay consistent with that plan.

It’s interesting. When you read the proposed Regs, it almost implies that you can’t modify your plan otherwise, it seems like you really, have there’s this strict adherence. And I know that most practitioners felt that QOZBs possibly could make reasonable modifications to address the commonly occurring changes in the business environment or the like. But when you read these new rules, it almost appears like the only out you have is this federally declared disaster issue, which again, applies pretty broadly now, but may not in the future. And so, as the working group, we actually commented on that section and asked for guidance around folks that might wanna modify their plan, maybe not so substantially, but just to address common occurrences in business environment. And so we’re hopeful that the Treasury does provide some guidance around smaller modifications, not necessarily, wholesale changes, that might or would declare disasters and the like.

Jimmy: Good something to keep an eye on there with respect to Working Capital Safe Harbor, which can really buy a lot of more time and flexibility with regard to QOF and QOZB investing. Mike, I wanna turn back to you now, one of the best services, I think that your firm Novogradac offers to Opportunity Zone stakeholders is the capital raising survey that you conduct on a rolling basis. You’ve been receiving survey data from a lot of the funds that you track for, I think, the better part of two years or over two years now what update do you have there for us?

Mike: Yeah, thank you for that. It’s definitely something that we enjoy being able to provide. And we would like to encourage all your listeners if they are fund managers or fund investors to please participate in the survey. It is voluntary, and it’s data that we’re able to collect sort of publicly that your listeners and other funds will share with us. They can just email CPAs at novoco.com if they wanna participate. It’s also a data that we collect through the SEC filings, and also through press releases and the like. But we just recently, and I guess not so recently now, but at the end of June or in I should say July, we released it in this data through the end of June. And we’re up to $17.5 billion in equity raised by opportunity funds. And we are tracking nearly 1200 funds right now. And we know the actual number of funds that are out there are three to four times of that, but the ones that we have information on are about 1200.

And now that we have actual capital, raising information on about 850 of those funds. So it’s a pretty expansive survey. And it’s pretty impressive that we’re at 17.5 billion that we’ve identified through the end of June already. And I will note that one of the questions we get a lot of is how much is residential, how much is commercial, and the other areas? And within residential, roughly 4 billion of that 17.5 is residential only, and about 14 billion of the 17.5 is at least partially residential. So clearly, residential continues to be a significant player. And I think that COVID definitely further skewed. I think, initially, we weren’t surprised that residential was so dominant. And then as went through COVID, we’re still not surprised that residents are so dominant, because it’s a little bit harder to underwrite commercial and particularly hospitality. Our categories are residential, commercial, hospitality, renewables, and operating businesses. And hospitality is a bit of a challenge in terms of funding during COVID. And then, but the other area that I think is of note in our survey results as operating businesses, they continue to be less than a billion, but the amounts did come close to doubling in the last surveys. So we’re definitely seeing an uptick in operating businesses. And I think operating businesses will always be in terms of dollar amounts serve a smaller amount, relative to some of the real estate sort of investments. But a lot of the operating investments are really impactful.

And the other thing of note for the survey is roughly half the funds are more than half the funds are focused on a single city. So you’re definitely seeing a large number of single city focus funds in only about 50 of the funds are nationwide. But for those 50 have a large amount of capital that they raise as you could expect. But I’d also note for the listeners, we do sell a full report that you can go to our websites and get a full report on the June 30 data. And our next reporting period will be December 31.

Jimmy: Fantastic, well, a lot of insightful data that you collect there and that you publish for us who are interested in this type of data. And just to be clear that number that you cited, the I think it’s…I can’t remember this number you said I’m looking at your website right now 17.5 billion it’s up to you right now, that is not the entire universe of qualified opportunity funds. That’s only the slice of the much larger pie that you’re able to get this voluntary data from. So we might expect that total number raised by qualified opportunity funds to date might be three times higher, four times higher, five times higher. What are your thoughts there?

Mike: Yeah, I do think it’s somewhere between three to four times higher. I mean, we do know that the Joint Committee on Taxation did release some information for the 2019 tax year. So we know that at the end of 2019, roughly over 19 billion had been invested in Opportunity Zones at the fund level. So that’s the actual investment data. And our 17.5 is equity raised, and that’s obviously, a long 2019 is a while ago. But we have the data from the Joint Committee on Taxation that looks at tax returns that were filed for 2019. And they found 19 billion that had been invested in Opportunity Zones. And the 2020 extended filing date for partnership returns just expired on September 15th. So we do expect some time in the middle of next year to have the investment data for 2020. And we do think it’s gonna be in the 30 billion plus range.

Jimmy: Yeah, it should be substantially higher. I would think that initial data from the Joint Committee on Taxation really only encapsulates the first roughly 18 months or so of Opportunity Zone investing if I’m not mistaken.

Mike: That’s exactly right.

Jimmy: So good. A lot of good news there on the capital raising front. I think the program’s gotten a lot of traction, a lot of momentum over the past few years and COVID put a little bit of a damper on things throughout 2020. But as capital gains continue to accrue in the stock market and in other asset classes and as the 10% to basis step-up is expiring at the end of this year. I’m expecting at least that momentum will continue in the positive direction for the Opportunity Zone Incentive Program. Do you see the same way?

Mike: Absolutely. There’s a recent deadline September 11th, was the deadline. So that will lead that we believe there’s a lot of investment in the last few months. And then we also expect a 10% basis step-up deadline at the end of this year, to also catalyze a lot of additional investment. So we are expecting the balance of this year to close very strong in the capital raising fund. And the good news with that is it’s not about raising capital, ultimately, the purpose of the incentive is to invest in distressed areas. And knowing that a lot of capital will get raised means we’re gonna see a lot of investment in distressed areas, which is great.

Jimmy: Absolutely. And that’s what that JCT report reported on correct?

Mike: That is correct.

Jimmy: That was aggregated, form 8996 data, which shows where the funds are then deploying the capital into, whereas your report is reporting on capital raising at the fund level from investors.

Mike: And just to emphasize ours is capital raised, not capital commitments, and they are assets dollars that have been invested in the fund.

Jimmy: That’s an important distinction.

Mike: The fund has that money to invest.

Jimmy: Very important distinction there. Let’s turn now to your Opportunity Zone Conference, you’re back in person. Finally, you’ve done I think it’s three, you did three Opportunity Zone events, virtually in 2020, and your spring conference in 2021. Now finally, on October 21, and 22, the Novogradac fall Opportunity Zone Conference is back in person it will be held at the Hilton Hotel in downtown Cleveland. What can you tell us about that conference? What are you looking forward to? And what should attendees expect?

Mike: Yeah, we are really excited to be able to be back in person. But I will note to our listeners, that will be in person and we will be streaming the events. So if you’re not comfortable going to a conference in person yet, and I certainly understand that there’s a large number of people that aren’t quite ready to do an in person event, we will be streaming it as well. So you get your choice of either on a live stream from the comfort of your home or your office, or you can be in person. And we are working on additional networking and such so that if you’re live streaming, you still get some of the networking benefits that obviously those are there in person will benefit a lot more from that networking potential.

And let me just say first off that your listeners do get a 10% discount. So simply go when you check out after you go to our website, and register, just use the discount code Novo OPP DB. In terms of the conference, we’re really excited, we’re gonna kick off with Washington wire report, we’re gonna discuss what’s happening back in Washington, DC. And either mid-October, a bill will pass where we talk about that, or we’ll be talking about where we stand in terms of getting some type of budget reconciliation bill passed and the impact it could have on Opportunity Zones. And then we’ll also discuss in more detail what could be happening in the legislative and regulatory front in the coming months. And we’re pleased to have Katherine Lyons with the Economic Innovation Group. And your listeners know the Economic Innovation Group is the central catalyst for Opportunity Zones.

And then also Shay Hawkins, formally with Senator Tim Scott’s office, and now the executive director of the Opportunity Funds Association. They’re also gonna have a session on the state of the marketplace that John Sciarretti is going be moderating and give an update on how fundraising is going investing and the like. We also have a session that we find a lot of potential businesses, those that are seeking investment to really find rewarding and useful, as well as those that are out there trying to form farms. And it’s a funds sponsor speak session, where qualified Opportunity Fund sponsor share what they’re looking for when they make investment decisions. And it’s also a chance to hear from those that are actually operating cost opportunity funds, and how to increase your chance of having your business seeking funding to get your proposal funded.

And then as always, we are an accounting firm. So we have sessions, very technical sessions. We have technical sessions on various tax issues that clients might have, as well as we have some attorneys on a session to deal with SEC and registration and the like. And so we have some of those technical panels, but we’re really excited to be back in person. And for anyone listening if there’s other questions they have or if they have suggestions, please email [email protected].

Jimmy: Fantastic. Well, I’m looking forward to it and I’d be remiss if I didn’t mention that there’s gonna be a pre-conference workshop also the day before the main event, which starts the main event goes from October 21 through October 22. But the pre-conference workshops are on October 20th. And my partner at OZ Pros, Mr. Ashley Tison is gonna be one of the speakers at that one of those workshops pre-conference as well. Anything you can add about that, Mike?

Mike: Thank you for mentioning that I meant to mention that as well. Because if you’re newer to Opportunity Zones, or want a refresher, or wanna just get more time with some of the experts, those are great sessions to attend. And that’s a great entry into there’s both a sort of a more of a basic session and an advanced session. So I would encourage your listeners to register for one or both of those.

Jimmy: Fantastic. Well, again, I’m looking forward to it. And as Mike did mentioned a minute ago, as a listener of the “Opportunity Zones Podcast,” you can get a 10% discount on tickets to the Novogradac event coming up in Cleveland in October by using the promo code NOVO OPP DB at checkout. That’s N-O-V-O O-P-P D-B. And Mike, where can our listeners go to learn more about you and John and all of the services that Novogradac provides.

Mike: They can go to novoco.com and just click on Opportunity Zones Resource Center. You also can find out about the working group there. You can find out about our conferences, and the like. Or you could just search Novogradac Opportunity Zones in Google…

Jimmy: That will also work.

Mike: Or Edge or whatever your favorite search engine is, and that will take you there.

Jimmy: Yeah, hard to miss. You guys are all over the place on the internet. Well done. Well, Mike, final question for you. You grew up in Los Angeles. You live in San Francisco now. Do you like the Giants or the Dodgers in the NL this year?

Mike: Oh, you’re gonna put me on the spot. I have clients that are Dodger fans. And I did grow up a big Dodger fan to the Davey Lopes, Ron Cey, Steve Garvey, Bill Russell infield years and Burt Hooton, and Reggie Smith and all the rest. So those that are longtime Dodger fans, I’m dating myself, but I’ve been in the Bay Area way too long. I’m a diehard Giants fan. So I’ll be rooting for the San Francisco Giants. And I’m actually hopeful that they’ll end up playing each other in the playoffs. I think the Dodgers and the Giants have never met in the playoffs. So I think that would be a wonderful turn of events.

Jimmy: This could be the year. Well, I’m looking forward to last few weeks of the baseball season. Thank you both for joining me today. For our listeners out there. As always, you can find show notes on today’s episode on the Opportunity Zones database website. You can locate those show notes at opportunitydb.com/podcast. And you’ll find links to all of the resources that Mike, John, and I, discussed on today’s show. And I’ll be sure to link to the Novogradac website and the website for the upcoming conference in Cleveland. Mike and John, thank you again for joining me today. Appreciate it.

Mike: Thank you Jimmy.

John: Thank you.

Jimmy: That’s it for our show today. A huge thank you to you, our listeners. If you liked this episode, please rate and review us on iTunes. The “Opportunity Zones Podcast” is produced by the opportunity database. Visit opportunitydb.com. to learn more about Opportunity Zones and Opportunity Zone Fund Investing. You can learn how to subscribe to this podcast and read more about today’s guest in the show notes by visiting opportunitydb.com/podcast and we’ll be back soon with another episode.