EFTA01375640

Why Invest in Opportunity Zones? Tax Benefits Impact ■ Tax Deferral of Capital Gains until 2026 - gain can come from almost any investment — stocks, bonds, real estate, art, business sale ■ Tax Reduction - rollover gain reduced by 10% or 15% if investment in the QOZ is held for at least 5 or 7 years, respectively ■ Tax Forgiveness - if held for >10 years, no tax on capital gain on the new investment ■ Applies to federal capital gains tax and most states capital gain tax ■ Potential to become the largest economic development and investment program in the last 30-40 years ■ Concentration of capital in specific Opp Zone locations has the potential to transform these communities over time and lift asset values ■ Real estate investment should stand on its own merits without the tax benefits ■ Investment in real estate development can enhance the risk/return profile of an investment portfolio and provide attractive returns typically less correlated to other asset classes ■ Inflation-protected alternative to highly valued stock market at late stage of the economic cycle • Recipients are urged to consult their own accountant for tax advice. 3 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) DB-SDNY-0071195 CONFIDENTIAL SDNY_GM_00217379 EFTA01375640