Molson Hart

In other words, GM could set up a plant in an OZ and the gains on that investment would be subject to TCJA tax breaks.

Pushback is could a global Co relocate HQs to an OZ and get the tax benefits? That doesn't see realistic imo.

But, in that example, what would be the investment? Essentially a new HQs bldg. Ok, so global gets 100% step-up on their bldg + depreciation over 10yrs. Legacy BV of Co would not be subject to TCJA benefits, just the new investment. That seems to work.

Generally speaking, participants are totally underestimating the impact of OZ on US Co capital investment decisions. Keep buying sub 5% cap NY office towers folks.

I thought oz only helped reduce long term capital gains. I don't see how'd theyd help a company relocating their hq to one.

b/c they'd get depreciation over the 10yr period and no recapture + any upside.

Yeah, but if I'm understanding you correctly, that's, on a percentage basis, a much smaller tax optimization than making your parent company an Irish entity let's say. I feel like the pop of companies big enough to have an HQ mostly would prefer to have their hq somewhere nice.

services sector will depend and i tend to agree w/ you but manufacturing or other capital intensive - it's a very big incentive. think medical device, pharma, robotics/tech.