Stock of any domestic corporation (i) acquired by the Opportunity Fund after December 31, 2017, at original issuance solely in exchange for cash, and (ii) which, at the time such stock is issued and during substantially all of the Opportunity Fund’s holding period, is a Qualified Opportunity Zone Business (“QOZB”).
If the corporation is newly formed, it does not need to constitute a QOZB on the date the stock is issued, but the corporation must be organized for purposes of being a QOZB. Stock does not qualify as Opportunity Zone Stock if the issuing corporation redeemed a significant amount of its stock within the two-year period beginning one year before the issuance to the Opportunity Fund, or redeemed any stock from the Opportunity Fund or a party related to the Opportunity Fund within a four-year period beginning two years before the issuance to the Opportunity Fund.