Information contained in presentation is provided for educational … · 2019. 5. 29. ·...

87

Transcript of Information contained in presentation is provided for educational … · 2019. 5. 29. ·...

Page 1: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 2: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 3: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Information contained in presentation is provided for educational purposes only. All

are advised to seek the counsel of an attorney and/or accountant for specific situations.

Page 4: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

WELCOME

Mayor Chasity Wells-Armstrong City of Kankakee

Page 5: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

INTRODUCTION OF KEY CITY

Jake Lee Key City CDC, Board Chair

Page 6: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 7: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Key City Community Development Corporation

Vision • To facilitate transformational growth within

Kankakee City Mission • To cultivate quality of life improvements

through long-term, sustainable, economic growth in areas of tourism, entertainment, culture, business development, and home ownership while maintaining the uniqueness of Kankakee.

Page 8: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Role of

Key City Community Development Corporation

•  Assist the Mayor in moving Kankakee forward though

Transformational Growth •  Key City C.D.C. will focus its efforts around four

components:

1.  Land 2.  Business 3.  Education 4.  Housing

Page 9: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Key City C.D.C. is Dedicated to Progress

Simple, short-term projects can test concepts and build momentum for larger revitalization efforts.

Page 10: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Business

Key City Will Develop an Entrepreneurial Ecosystem

•  Create an environment where people want to do business and then identify and support entrepreneurs.

•  i.e. Pop Up Retail, commercial enterprises •  Shared Workspace •  Arts & Culture •  Entertainment enterprises

Page 11: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Small Business Education •  Key City C.D.C. will partner with the local college and subject

matter experts to create an intensive small business planning and accelerator program for new and existing businesses

•  Key City will assess (individual and/or small business) and create an MBA level curriculum designed to assist businesses in writing fundable business plans, counseling and a toolkit to prepare them for success.

•  Graduates (advanced) may qualify for SBA loan or CRF loan as start up capital

•  Key City will also work with TIF resources to create workforce development programs providing skilled workforce.

Page 12: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Housing •  Key City will work to develop various housing

alternatives from single family, rental, seniors and will target various demographic and income groups :

•  Veterans • Millennials •  Seniors •  Families • College Students •  Single Adults •  Professionals

Page 13: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

OPPORTUNITY ZONE PRINCIPLES

Scott Styck & Karen Benson, CPAs Smith, Koelling, Dykstra & Ohm, P.C.

Page 14: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 15: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 16: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 17: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 18: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 19: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 20: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 21: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 22: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 23: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 24: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 25: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 26: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 27: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 28: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 29: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 30: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 31: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

SMALLER PROJECTS

Dave Baron Key City Board Member

& Attorney, Deck & Baron

Page 32: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Information contained in presentation is provided for educational purposes only. All are advised to seek the counsel of an attorney and/or accountant for specific situations.

LAWYER DISCLAIMER!

Page 33: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Opportunity Fund Tax Calculator: https://opportunitydb.com/tools/calculator/

Return PotentialHere’s what $100 worth of capital gains would return

In 10 years, after taxes collected, assuming 7% investment appreciations https://eig.org/wp-content/uploads/2018/02/Opportunity-Zones-Fact-Sheet.pdf

$132 $176vs.in a traditional stock portfolio by investing in an Opportunity Fund

Page 34: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Types of Opportunity Funds

• Outside Investor Funds • Local Investor Funds • Funds of $ Billions • Funds of $ Thousands

All self-certify using the same IRS Form 8996

• Pooled Funds • Single Investor Funds • Multiple Project Funds • Single Project Funds

Page 35: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Comparison to 1031 Exchange1031 Exchange •  Like-Kind Exchange Required •  Restricted Types of Property •  No Liquidity •  Perpetual Deferral of capital

gains tax •  Step-Up Basis upon Death

Opportunity Fund Investment •  Like-Kind Exchange Not Required •  Any Capital Gains Realized •  Available Liquidity •  Must pay (potentially reduced) capital

gains tax in 2026 •  Heirs receive tax benefit upon death •  Elimination of capital gains tax on

appreciation on investment

Page 36: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Example 1: Residential Rehab•  Property manager creates new LLC as Opportunity

Fund and injects capital gains (hers or someone else’s) or other sources of funding (loan, debt, pocket change)

•  Fund purchases single family residential property and substantially improves it (spends double the value) using capital gains or other sources

•  Manager receives regular income from rent •  After 10 years, no capital gains tax on any

appreciation to property •  Same process for commercial properties, mixed-use

multiple tenants, etc. City of Kankakee, Median Sales Price for Single Family Traditional Sales

Past 12 Months = 21.2% Increase. Past 36 Months – 47% Increase

Page 37: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Example 2: Business Expansion• Existing Biz creates new LLC to qualify as

Opportunity Fund and invests capital gains • Fund purchases real estate and substantially

improves the property • Fund serves as Holding Co. and permits

Existing Biz to lease the property

Page 38: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Example 3: Start Ups

• Angel Investor •  Investor with capital gains creates LLC

certified as Opportunity Fund to purchase shares in a New Biz

•  Incubator • See Example 1 and apply to new

commercial property

Page 39: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

LARGER PROJECTS

Frank Koehler, City of Kankakee Tim Nugent, Economic Alliance

Scott Snavely, Midland States Bank

Page 40: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

KANKAKEE OPPORTUNITY ZONE

Availability of Opportunity Zone, Tax Increment Financing, Enterprise Zone, Historic Tax Credits, and other benefits

Page 41: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 42: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

KANKAKEE OPPORTUNITY ZONE • DOWNTOWN RIVERFRONT MASTER PLAN –

PROPOSED PUBLIC IMPROVEMENTS:

•  Lighting on Key Bridges •  Streetscape Enhancements •  White Water Run •  Kayak/Canoe Launches •  Festival/Entertainment Venue •  Linear Bike Way / Pedestrian Walkways •  Pavilions, Gardens, Enhanced Landscaping

Page 43: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

KANKAKEE OPPORTUNITY ZONE

•  PRIVATE INVESTMENT SCENARIO’S •  Market Rate Multi Family Residential •  Mixed Use Residential/Commercial/Office •  Senior Citizen Housing •  Lease to Own Townhome/Duplex Developments •  Corporate Offices / R & D Facilities •  Small to Mid-sized Manufacturing/Industrial Uses •  Distribution / Logistic Facilities •  Restaurants •  Hotels

Page 44: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 45: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 46: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 47: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

KANKAKEE OPPORTUNITY ZONE FOR MORE INFORMATION, PLEASE CONTACT:

FRANK KOEHLER ECONOMIC DEVELOPMENT DIRECTOR

CITY OF KANKAKEE 850 N. HOBBIE AVENUE

KANKAKEE, ILLINOIS 60901 815.933.0488

[email protected]

Page 48: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Kankakee Riverfront OZ Basics Thursday,May16,2019KankakeePublicLibrary

Page 49: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are
Page 50: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Clicktodownloadcomplete2019KankakeeCountyMarketProfile

Page 51: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

City of Kankakee: A Vital Role •  HistoricDowntownDistrict

•  RiverfrontMasterPlannedArea

•  MedicalCorridor

•  Government/CivicCenter

•  Employment&EntrepreneurshipHub

•  CommunityGateway

•  Market-rateMultifamilyResidential(Unmetdemandfor800+units)

•  Hospitality&Recreation

•  Office,incl.Co-working&Incubation

•  NicheManufacturing&Retail

•  BusinessServices

Page 52: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Clickimagetoaccess40+OZpropertiesKankakeeRiverfrontOZPropertyPortal

Page 53: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Clickimagetoaccess40+OZpropertiesKankakeeRiverfrontOZPropertyPortal

Page 54: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Clickimagetoaccess40+OZpropertiesKankakeeRiverfrontOZPropertyPortal

Page 55: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Clickimagetoaccess40+OZpropertiesKankakeeRiverfrontOZPropertyPortal

Page 56: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Clickimagetoaccess40+OZpropertiesKankakeeRiverfrontOZPropertyPortal

Page 57: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Contacts TimothyNugent LisaWogan

President/CEO VicePresident,Marketing

[email protected] [email protected]

Page 58: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Opportunity Zone Basics

Page 59: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

OZ Funding Stack-Midland Example PROJECT SOURCES

Owner Equity Private Equity Grants Cash __________________ 1,000,000 Total Owner Equity 1,000,000 10% OZ Funds 7,000,000 70% Midland Debt 2,000,000 20% Subordinate Debt 0% ___________________ Total Sources of Funds 10,000,000 100%

Owner’s Equity

1,000,000 10%

OZ Funds

7,000,000 70%

MSB Debt 2,000,000

20%

LLC

LLC purchases a building. Substantially improves the property.

Fully amortizing Ten years/20 year amortization Market Interest Rates Mitigates Refinance Risk

Land500,000AcquisitionCost2,500,000ConstructionCosts5,000,000SoftCosts1,500,000Contingency500,000TotalUsesofFunds10,000,000

PROJECT USES

Page 60: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

COMMERCIAL LOAN TYPES CommercialRealEstate

•  RetailwithCreditAnchor•  RetailwithoutCreditAnchor•  Multi-Family•  Office–OO•  Office–NOO•  Industrial–OO•  Industrial–NOO•  Warehouse–OO•  Warehouse–NOO•  SeniorCare•  Hotel/Motel(mid-tierorhightier

flag)•  GasStation/CarWash/C-Store•  SpecialUse•  NewConstruction/Rehabfinancing•  SBA504/FHAw/LoveFunding/TIF

EquipmentFinance(LeasedorFinanced)

•  GuidanceLineformultipleperiodicpurchases

•  AgricultureEquipment•  MunicipalVehicles(Police,Fire,

Ambulance,Fleet)•  Industrialorlightdutyequipment•  Tractor/Trailer•  ConstructionEquipment•  MedicalEquipment•  Computers/Software,etc.OperatingLines

LinesofCreditforWorkingCapital/CashFlow

Page 61: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

LOVE FUNDING KNOWLEDGE. INTEGRITY. RESULTS.

FHA FINANCE SOLUTIONS Multifamily | Healthcare | Hospital

LOAN PROGRAMS

Love funding provides refinance, acquisition, construction, rehabilitation and bridge loans for market-rate multifamily and affordable housing communities, healthcare facilities and senior housing, as well as hospitals. In the last 2 years, we’ve closed nearly $1.8 billion in HUD-insured financing for our valued clients.

www.lovefunding.com

Page 62: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

BENEFITS OF FHA FINANCE There are a lot of finance options out there, but we firmly believe in the many benefits of FHA financing. In fact, we focus exclusively on HUD-insured loan programs and have the knowledge and expertise to show for it. ü  Low, fixed interest rate

ü  Non-recourse ü  Fully assumable ü  Long-term amortization

ü  Flexible pre-payment structure

BRIDGE LOAN PLATFORM Love Funding offers a bridge-to-HUD loan platform as an interim financing option when quicker executions are required or HUD

regulations dictate the need for interim financing.

Page 63: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Midland States Bank R. Scott Snavely

Market President II Kankakee County, Beecher, Dwight

310 S. Schuyler Ave. Kankakee, IL 60901

815.465.7275 [email protected]

www.midlandsb.com

Brent Frank Love Funding 815-230-4370

[email protected]

Page 64: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

FUND ADMINISTRATION & EQUITABLE DEVELOPMENT

Linda Crane Protagonist Capital LLC

Page 65: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Protagonist Capital LLC Key City CDC

“Opportunity Zone Basics: Using the New Incentive to Support Large and Small

Projects”

Thursday,May16,2019KankakeePublicLibrary

Kankakee,Illinois

ForEducationalPurposesOnly.

CONFIDENTIAL-PROTAGONISTCAPITAL©2019

64

Page 66: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Opportunity Zones Overview

PROTAGONISTCAPITALLLC

Alternative Financing Solutions

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

65

www.protagonistcap.com

Page 67: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Who is Protagonist Capital?

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019 66

FoundedbytwoofChicago’sleadinglawyers,MichaelO.BrownandLindaR.Cranetopursuetheirvisionofafirmthatreinventsthealternativefinancingindustryandhasastrongpositiveimpactonthecommunitiesinwhichtheyoperate.

ProtagonistCapitalisadiversefirmthatoffersitsclientsdirect,oftenexclusiveaccesstorealestate,privateequity,andsecondarymarketassetsalongwithcomprehensivebackofficeadministrationandaccountingservices.

Page 68: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

What Are Opportunity Zones?

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

67

SponsoredbySen.TimScottofSouthCarolina,andpassedbyCongressasapartoftheTaxCutsandJobsActof2017,TheOpportunityZoneActencourageslong-terminvestmentsinlow-incomeurbanandruralcommunitiesthroughouttheU.S.anditsterritories.Itisintendedtostimulateinvestmentandeconomicdevelopmentindesignatedareasknownopportunityzones..

TheActprovidesapowerfulwayforinvestorstoshelterrealizedcapitalgainsbyre-investingthemintoqualifiedOpportunityFunds.Purposeistobeusedasacommunityinvestmenttool.

Tosummarize:OpportunityFundsinvestinOpportunityZoneBusinessesthatarelocatedinsideofOpportunityZones.

Page 69: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Community Playbook for Opportunity Zone Projects •  BipartisansupportofTaxCutsandJobsActof2017(legislationchampionedbySens.TimScottandCoreyBooker).

•  ThepotofpotentialcapitaleligibleforreinvestmentinOpportunityZonesclimbstoatotalof$6.1trillion(Forbes,July18,2018).

•  Newandexpandingbusinesses,affordablehousing,infrastructure,energy,commercialdevelopments,orjustaboutanythingelsethatcreatesproductiveeconomicactivity.

•  Needtoassessneighborhoodtypesandmatchstrategiesaccordingly.

•  RethinkROIfornontraditionalinvestmentcommunities.

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONIST

CAPITAL©2019

68

Page 70: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

The Designation of Opportunity Zones ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONIST

CAPITAL©2019

69

1

EachStatenominatedcensustractstobedesignatedasOpportunityZones.

2

MustbeapopulationcensustractwithinaStatethatqualifiesasalowincomecommunity.

3

Somestateshavedesignatedsomenon-lowincomecommunitiesasOpportunityZones(thistractiscontiguoustoalowincomecommunitydesignatedasanOpportunityZone).

Page 71: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Opportunity Zones Census Tract Qualifications

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

70

Povertyrateof20%orhigherormedianhouseholdincomethatislessthan80%ofthethesurroundingarea.

Governorswereallowedtodesignate25%oftheirstates’eligibletractsasOpportunityZones

Nationwide,about8,700areas,havebeenapprovedasopportunityzones

Page 72: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Illinois Opportunity Zones

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

71

Page 73: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Illinois Opportunity Zones

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

72

Page 74: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Chicagoland Opportunity Zones

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

73

Page 75: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Three Tax Benefits from Investing in Opportunity Zones

1.   Deferralofinitialcapitalgainsfromrecentsales.2.  Eliminationofaportionofgainsfromrecentsalesreinvestedin

qualifiedopportunityzonefundinterestupon5th(10%initialcapitalgaineliminated)and7th(additional5%ofinitialcapitalgaineliminated)yearanniversary.

•  Upto15percentofthegainsrealizedfromrecentsalesorexchangesandreinvestedinaqualifiedopportunityfundcanbeeliminated.

•  InvestormayonlydeferinvestedinitialgainuntilDecember31,2026.

3.OpportunityZoneprojectgaintax-freeafter10thanniversaryoftheinvestment.

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

74

Page 76: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

90- Percent Test

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

75

QualifiedOpportunityFund

Atleast90percentofitsassetsinqualified

opportunityzoneproperty.

10%ofassetsmaybeinvestedelsewhere.

Fundmustmeetcompliancerequirements(atsix-monthperiodofthetaxableyearandatendoftaxyear)

Page 77: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Proposed Opportunity Zones Regulations ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONIST

CAPITAL©2019

76

70%ofbusinessassetsinZone“issubstantially

all”

OpportunityFundshave31monthstoinvest

Treatmentofland–doesn’t

countin“substantial

improvements”

Page 78: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Types of Qualified

Opportunity Zone Property

Interests

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

77

Qualifiedopportunityzonefundstock–investin

opportunityzonecorporation.

Qualifiedopportunityfundzonepartnershipinterest–

capitalinterestinOZpartnership

Qualifiedopportunityfundzonebusinessproperty

Tangibleproperty

i)originaluse–“ground-up”development

ii)substantialimprovement–30-monthperiodtimeframe.

Noteligible:commercialgolfcourse,countryclub,massageparlor,hottubfacility,suntanfacility,racetrack,gamblingfacilityorliquorstores.

Page 79: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Limitations on Investments

•  Mustinvestallcapitalgainsintothefundwithin180daysofsaleorexchangetransaction.

•  Nominimumormaximuminregulationslimitsontheamountsofcontribution.

•  Investorscaninvestpersonalmonieswithcapitalgainscontributiontotheopportunityzonefund,butwillonlyreceivetaxbenefitsfromcapitalgainscontribution.

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

78

Page 80: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Potential Steps to Avoiding the Negative Effects of Gentrification

Townsadoptandenforcezoningandaffordable-housinglawsasnewcapitalflowsintothecommunity.

Leadersmustensurethatalargeportionoflocalsarehiredtobuildandservicenewprojects

Localgovernmentcantakethenewpayroll-taxandproperty-taxrevenuesandreinvesttheminthecommunitytoimprovebasicservicesand

infrastructure.

Investorscanoffercheaprenovationloansandsubsidizedmortgagessolocalcommunitycanbenefitfromrisingpropertyvaluesinsteadofgetting

pricedout.

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

79

Page 81: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Why Protagonist Capital?

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

80

Ourteam’sbusinessprincipalssupportedby70+yearsoflegalanddevelopmentexperience.

Offercreativealternativefinancingsolutionsfor:

• OpportunityZoneFinancing;• EB-5Funding;• TaxIncrementFinancing;and• Foreigndirectinvestmentblendedwithdebtfunding.

Purpose-builtbackofficefundadministration.

• Leadingindustry-leadingsolutionstospecializedfinancialtransactions,ourteamoffersanunsurpassedlevelofcustomerservicetoOpportunityZoneFundandalternatefinancingmanagersandtheirinvestors

Page 82: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Our Menu of Services

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

81

OpportunityZoneFinancing

EB-5Financing

NewMarketTaxCreditFinancing

Consulting

CommunitySupportInitiatives

Page 83: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Funding of Projects

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

82

ProtagonistCapitalcanassistfundingofyourprojectwithcomparativefinancialmodelingandnon-traditionalsourcesoffunds.

ProtagonistCapitalcanadviseandconsultregardingyourprojectssuitabilityasapotentialOpportunityZone,EB-5,foreigndirectinvestmentortax-incrementfinancingproject.

Page 84: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

MichaelBrownManagingPartner LindaCrane

ManagingPartnerElizabethBleakleyGeneralCounsel

MichaelJanniereVPofOperations

PROTAGONISTCAPITALTEAM

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019 83

Page 85: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

84ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

Page 86: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

Contact Information

LindaR.Crane,ManagingMember

55WestMonroeStreet,Suite3600Chicago,Illinois60603-5026Office:312-675-4256Email:[email protected]

ForEducationalPurposesOnly.CONFIDENTIAL-PROTAGONISTCAPITAL©2019

85

PROTAGONISTCAPITALLLC

Investing Towards Stronger Communities

www.ProtagonistCap.com

Page 87: Information contained in presentation is provided for educational … · 2019. 5. 29. · Information contained in presentation is provided for educational purposes only. All are

GRAPES & HOPS 251 South Schuyler Avenue

All are invited to continue the conversation at