Two Channels, One Deal: Opportunity Zone Structuring for Sponsors and Investors

In this Masterclass, OZ attorney Gerry Reihsen of Reihsen & Associates breaks down the multi-capital channel framework for Opportunity Zone deal structuring — showing how a single QOZB can simultaneously serve passive investors through a sponsor-managed QOF and sophisticated investors through their own self-directed “Captive” QOF — equipping sponsors, advisors, and investors with the tools to structure compliant, high-performing OZ investments on both sides of the OZ 2.0 transition.

What’s covered:

• The bonus technique: how purchasing an existing QOF interest can unlock OZ 2.0 treatment for capital already deployed
• The two-channel structure: how Sponsor QOFs and Captive QOFs co-invest in the same QOZB on identical economic terms
• Entity roles and economics: GP, developer/investment manager, the QOZB as the deal’s financial core, and the 0.1% manager mechanism that makes a QOF “captive”
• OZ 1.0 vs. OZ 2.0: what changes in 2027 and why it matters for investments being structured today
• Three strategies for capturing OZ 2.0 benefits with 2026 investments — including installment sales, mid-year gains, and K-1 entity timing