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Opportunity Zone Fund Investing Entering A Virtuous Cycle

Stronger Economy Should Bolster Demand For Luxury Rentals

The narrative surrounding the U.S. economy is taking on a more positive tone of late as major Wall Street banks are tempering their fears of a major economic slowdown.

In a research note published earlier this month, Goldman Sachs lowered its probability of a U.S recession in the next 12 months to 15%, down from an earlier probability of 20%. “The continued positive inflation and labor market data led to the cut,” Goldman Chief Economist Jan Hatzius wrote. Goldman expects reacceleration in real disposable income next year “on the back of continued solid job growth and rising real wages.”

We believe that this latest commentary from Goldman is not simply good news for the overall economy, but also implies home prices holding steady with the likelihood of seeing upward momentum in 2024 if there is in fact a reacceleration of disposable income. We also believe that it may imply the Fed will maintain higher rates for longer, thus keeping mortgage rates at levels that make affording a home a challenge for millions of Americans, and for many others, completely out of reach.

Against this backdrop, one could argue that Class-A full-featured multi-family housing complexes in prime locations may continue to benefit from macro housing headwinds.

Belpointe PREP, LLC (“Belpointe OZ”) (NYSE American: OZ), is the only qualified opportunity fund (“QOF”) listed on a national securities exchange, with its first two multi-family housing projects (currently under construction) located in downtown Sarasota and St. Petersburg, Florida, respectively.

Opportunity Zones were created under the Tax Cuts and Jobs Act of 2017, and now in their sixth year, are potentially poised to be expand further with several Congressional bills on the 2023 fall agenda. For example, on June 7, 2023, Representatives Drew Ferguson, Randy Feenstra, David Kustoff and Carol Miller introduced the “Rural Opportunity Zone and Investment Act” (H.R. 3906) into the House Committee on Ways and Means, and, on June 9, 2023, Representative Jason Smith introduced the “Small Business Jobs Act” (H.R. 3937) into House Committee on Ways and Means, which was thereafter sent to the full House for consideration (together, the “Rural OZ Bills”). The Rural OZ Bills would, among other things, seek to establish “qualified rural opportunity zones,” in rural counties throughout the United States as well as establish certain minimum information reporting requirements for qualified opportunity funds (“QOFs”). In addition, on June 13, 2023, Representative Garland Barr introduced the “Opportunity Zones Enhancement Act of 2023” (H.R. 4055) (“OZ Enhancement Act”) into House Committee on Ways and Means, which seeks to exclude interest on loans to qualified opportunity zone businesses from gross income.

With the introduction of the Rural OZ Bills, the opportunity zone fund program may reach well beyond just those urban areas of economic stress; the new proposal would designate 1,926 rural census tracts as rural OZs. In addition, as currently proposed the Rural OZ Bills would mimic much of the original OZ program: gains invested in rural OZs would not be recognized on the federal level until December 31, 2032, or until the investment is sold or exchanged, whichever occurs first; investments held for at least 5 years would be eligible for a 10% step-up in basis; investments held for at least 7 years would be eligible for a 15% step-up in basis; investments held for at least 10 years would be eligible for a basis adjustment to the fair market value on the date of sale or exchange, and so on.

As we see it, the economic gains being made in thousands of communities stem from embracing the virtuous cycle created by OZs, where future progress is compounded. According to a research review by the Economic Innovation Group (EIG), a bipartisan public policy organization, “[t]otal OZ equity investment reached at least $48 billion by the end of 2020 … [and] OZ designations improved local home values by 3.4 percent from 2017 to 2020 with no observed increase in rents.”

It is our view that legislation like the Rural OZ Bills and the OZ Enhancement Act, coupled with reports like the EIG’s are a big plus for all OZ developers.

On the development front, you should be aware that Belpointe OZ has just released a brand-new website for its Aster & Links project. Aster & Links is situated at 1991 Main Street, located in the heart of downtown Sarasota, Florida, in close proximity to the world-famous St. Armand’s Circle and Longboat Key. It’s a very exciting time for Belpointe OZ, in that this Class-A full-featured complex is rapidly coming to life, and investors and future tenants, who are projected to begin moving in in the spring of 2024, can now see first-hand how the project management team has gone to great lengths to bring a luxury living experience to Aster & Links.

Belpointe OZ is also making excellent headway on Class A multi-family residential project in downtown St. Petersburg, Florida, at 1000 First Ave North (previously referred to as 902-1020 First Avenue North). Click on the link below to review Belpointe OZ’s current properties in the various phases of conception of the project, remodel, ground-up construction, and acquisition.

From a tax planning standpoint, we think laddering capital gains tax deferment throughout the year by taking advantage of the QOF regulation’s rolling 180-day look-back period, can be very advantageous come the year-end. Most forms of capital gains qualify for tax deferment—stocks, bonds, mutual funds, ETFs, real estate, the sale of a business, trademarks, patents, cryptocurrencies, precious metals, collectibles, livestock, cars, aircraft, marine craft, etc. In the meantime, the potential growth and income from capital gains reinvested into a QOF have an opportunity to be compounded free of taxation as long as the QOF investment is held for at least 10 years through December 31, 2047.

Another key point: there is no limit on how much in realized capital gains one can reinvest into a QOF. QOFs, like Belpointe OZ, offer investors looking to shelter capital gains a viable opportunity. As part of the program structure, most taxable gains invested in a QOF are not recognized (on the federal level and in many states) until December 31, 2026 (due with the filing of the 2026 return in 2027), or until an investor’s interest in the QOF is sold or exchanged, whichever occurs first. The potential to compound growth and income thereafter within QOFs on a tax-free basis expires December 31, 2047.

On September 1, 2023, Belpointe OZ announced its unaudited quarterly net asset value (“NAV”) as of the quarter ended June 30, 2023, of $351.6 million or $98.58 per Class A unit, as compared to the current market price of around $90 per unit as of September 12, a meaningful discount to NAV. With many sectors of the market in correction mode, it might prove to be an excellent opportunity to book some profits, especially in market leaders that have enjoyed huge runs year-to-date, and to shelter those capital gains in a QOF, like Belpointe OZ where the construction of two large-scale multi-family residential projects in Sarasota and St. Petersburg, Florida, are making excellent progress towards completion in 2024.

A Viable Alternative to 1031 Tax-Free Exchanges

We continue to see ongoing interest from property owners about how Belpointe OZ might represent an attractive alternative to Internal Revenue Code Section 1031 like-kind exchanges. Investors that have sold real estate within the past 180 days and that may be under pressure to comply with Section 1031 regulations in order to complete a tax-free exchange, may want to avoid the inconvenience of having to identify a replacement property (and one or more alternative replacement properties, just in case a replacement property falls through) within 45 days of selling the original property, escrowing the sale proceeds with a 1031 qualified intermediary, and closing on a replacement property within 180 days of the sale of the original property. Instead, investors may want to consider investing capital gains from the sale of the original property into a QOF, like Belpointe OZ.

Attention Broker-Dealers: Here’s An Attractive Proposition For You

On May 17th, Belpointe OZ announced the commencement of an offering to raise up to $750 million in capital. This latest offering affords broker-dealers the opportunity to participate in the selling group, and Belpointe OZ has retained Emerson Equity LLC as dealer manager for the offering. Interested broker-dealers may contact us at or call 203-883-1944 for further information.

Further, in its effort to disrupt the U.S. real estate industry, Belpointe OZ is charging among the lowest fees in the market, including:

• No investors servicing fees;
• No disposition fees;
• 0.75% annual management fee; and
• 5% carried interest.

Belpointe OZ
255 Glenville Road
Greenwich, CT 06831
T: (203) 883-1944

The information in this communication is for illustrative, educational and informational purposes only and is subject to change. Nothing in this communication is or should be construed as an offer to sell or the solicitation of an offer to buy any securities. Offers may only be made by means of a prospectus.

Belpointe PREP, LLC (“Belpointe OZ”) has filed a registration statement (including a prospectus) with the SEC for the offering to which this communication relates. Prior to making an investment decision, you should read Belpointe OZ’s prospectus and the other documents that it has filed with the SEC in their entirety, and carefully consider its investment objectives and strategy, risk factors, fees and expenses and any tax consequences that may results from an investment in the offering. Copies of these documents can be obtained free of charge from or or from any broker-dealer participating in the offering.

The information in this communication should not be relied upon as investment or tax advice. You should consult with your own investment and tax advisers concerning the federal, state and local income tax consequences of purchasing, owning or disposing of securities in the offering, and of Belpointe OZ’s election to qualify as a partnership and qualified opportunity fund for federal income tax purposes. There is no guarantee that Belpointe OZ will continue to qualify as a partnership or qualified opportunity fund.

Past performance is not an indicator or a guarantee of future performance. An investment in the offering to which this communication relates involves a high degree of risk, including a complete loss of your investment, and may not be suitable for all investors. The price of Belpointe OZ’s securities will fluctuate in market value and may trade above or below net asset value. Brokerage commissions and expenses will reduce returns.

The offering to which this communication relates is being made on a best-efforts basis on behalf of Belpointe OZ through Emerson Equity, LLC, Member FINRA, SIPC, as managing broker-dealer.

©2023 Belpointe PREP, LLC. All rights reserved.

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