To quality, the OZ Fund invests directly in qualified opportunity zone business property, which is tangible property used in a trade or business of the OZ Fund that meets all of the following requirements:
• The OZ Fund acquired the business property by purchase from unrelated persons after December 31, 2017.
• The original use of such business property commences with the OZ Fund, or the OZ Fund
substantially improves the property.
• During substantially all of the OZ Fund’s holding period for such business property, substantially all of the use of that business property was in the Opportunity Zone.
Substantial improvement means that the OZ Fund makes capital expenditures with respect to the business property at least equal to the business property’s acquisition cost during any 30-month period.