Initial and Annual Statement of                                                       OMB No. 1545-0123
Form 8997                        Qualified Opportunity Fund (QOF) Investments
                                 ▶
Department of the Treasury         Go to www.irs.gov/Form8997 for the latest information.                                Attachment 2021
Internal Revenue Service                            ▶ Attach to your tax return.                                         Sequence No. 997
Name                                                                                                Tax identification number (see instructions)

Part I          Total QOF Investment Holdings Due to Deferrals Prior to Beginning of Tax Year 
                If different from last year’s ending QOF investment holdings, attach explanation.
     (a)                 (b)                          (c)                                 (d)              Deferred gain held in QOF
Qualified         Date QOF              Description of QOF investment                     Special          (e)                    (f) 
Opportunity       investment       (for example, 100 shares     or 25% interest)          gain      Amount of short-term Amount of long-term 
Fund (QOF)        acquired                                                                code          deferred gain        deferred gain 
     EIN          (MM/DD/YYYY)                                                                      remaining in QOF     remaining in QOF

1    Enter the totals, if any, from continuation sheet  . .     .  .   . .      . . . . . . ▶

2    Enter the totals from columns (e) and (f)  . . . .   .     .  .   . .      . . . . . . ▶
Part II         Current Tax Year Capital Gains Deferred by Investing in QOF
     (a)                 (b)                          (c)                                 (d)           Deferred gain invested in QOF
Qualified         Date QOF              Description of interest acquired                  Special          (e)                    (f) 
Opportunity       investment       (for example, 100 shares     or 25% interest)          gain      Amount of short-term Amount of long-term 
Fund (QOF)        acquired                                                                code          deferred gain        deferred gain 
     EIN          (MM/DD/YYYY)                                                                      remaining in QOF     remaining in QOF

1    Enter the totals, if any, from continuation sheet  . .     .  .   . .      . . . . . . ▶

2    Enter the totals from columns (e) and (f). See instructions for reporting on Form 8949 ▶
Applicability of Special Rules Regarding the Waiver of Certain Treaty Benefits
Are you a foreign eligible taxpayer whose tax year began after March 13, 2020? See instructions for more information. 
     Yes. You may not elect to defer tax on an eligible gain by investing in a QOF unless you check “Yes” in response to the next question. 
     No. Skip the next question and go to Part III. 
If you are a foreign eligible taxpayer, see the instructions to determine if you are required to attach a written statement for the portion 
of your first tax year ending after December 21, 2017, and all tax years that began after December 21, 2017, and on or before March 
13, 2020.
Waiver of Treaty Benefits on Future Inclusions by a Foreign Eligible Taxpayer (for Tax Years Beginning After  
March 13, 2020, Only)
Do you hereby irrevocably waive any benefits available under an applicable U.S. income tax convention that would exempt gains 
that you are deferring by investing in a QOF from being subject to federal income tax at the time of inclusion? See instructions for 
more information. 
     Yes. Report the deferral of the eligible gain in Part II and on Form 8949.
     No. You may not elect to defer tax on an eligible gain by investing in a QOF. Do not report the deferral of any otherwise 
     eligible gain in Part II or on Form 8949. 
For Paperwork Reduction Act Notice, see your tax return instructions.                   Cat. No. 37821R                      Form 8997 (2021)

Form 8997 (2021)                                                                                                                                     Page 2 
Part III        Inclusion Events and Certain Other Transfers During the Current Tax Year
                                                                                                                             Deferred gain included 
  (a)            (b)                                  (c)                                                 (d)      due to disposition of QOF interest
Qualified        Date of event                    Description of event                                    Special 
Opportunity      (MM/DD/YYYY)   (for example, sale of 100 shares, gift of 25% interest,                   gain            (e)                  (f) 
                                                                                                                   Amount of previously Amount of previously 
Fund (QOF)                           or distribution of     $1,000, etc.)                                 code     deferred short-term  deferred long-term 
  EIN                                                                                                              gain now included in gain now included in 
                                                                                                                   taxable income       taxable income

1    Enter the totals, if any, from continuation sheet  . .  .  .      . .   . . . . .                    . ▶

2    Enter the totals from columns (e) and (f). See instructions for reporting on Form 8949 ▶

Check this box if you disposed of any investment(s) and didn’t receive a Form 1099-B reporting the disposition from the QOF or 
other third party. See the Instructions for Form 8949 for reporting requirements of any gain or loss.
Part IV         Total QOF Investments Due to Deferrals at Year End (see instructions)
  (a)            (b)                                  (c)                                                 (d)      Deferred gain invested in QOF investment
Qualified        Date QOF            Description of interest acquired                                     Special         (e)                  (f) 
Opportunity      investment     (for example, 100 shares     or 25% interest)                             gain     Amount of short-term Amount of long-term 
Fund (QOF)       acquired                                                                                 code     deferred gain        deferred gain 
  EIN            (MM/DD/YYYY)                                                                                      invested in QOF      invested in QOF

1    Enter the totals, if any, from continuation sheet  . .  .  .      . .   . . . . .                    . ▶

2    Enter the totals from columns (e) and (f)  . . . .   .  .  .      . .   . . . . .                    . ▶
                                                                                                                                        Form 8997 (2021)

Form 8997 (2021)                                                                                                            Page 3 

Section references are to the Internal      Special gain code (SGC). An SGC is a        Identification requirement for 
Revenue Code unless otherwise noted.        code that is entered when the QOF           acquisition from another taxpayer in a 
                                            investment originated from an elected       noninclusion transfer. If you acquired 
General Instructions                        deferred gain, where the gain was:          the QOF investment during the tax year 
                                                                                        or in a prior tax year in a transaction that 
                                            SGC           Gain Origination
Future Developments                                                                     was, in whole or in part, not an inclusion 
                                            A      Section 1256 gain                    event under Regulations section 
For the latest information about            B      Form 4797 (section 1231)             1.1400Z2(b)‐1(c), provide the following 
developments related to Form 8997 and                                                   information relating to the transferor of 
its instructions, such as legislation       C      Straddle(s)
enacted after they were published, go to    D      Collectibles                         the QOF investment. Enter in column (c) 
                                                                                        the taxpayer name, taxpayer 
www.irs.gov/Form8997.                           E  Exempt by treaty (but for            identification number, and the date the 
                                                   election to defer rather than        QOF investment was transferred to you. 
Purpose of Form                                    claim exemption)                     Enter in column (d) special gain code 
The Tax Cuts and Jobs Act (TCJA),               F  Deferred gain relating to a non-     “F.”
section 13823, added section 1400Z-1               inclusion transfer                   Identification requirement for transfer 
to provide for the designation of certain                                               to another taxpayer in a noninclusion 
census tracts as qualified opportunity      Who Must File
                                                                                        transfer. If you disposed of a QOF 
zones (QOZs) and added section              An eligible taxpayer holding a QOF          investment during the tax year in a 
1400Z-2 to provide certain benefits for     investment at any point during the tax      transaction that was, in whole or in part, 
investments in these QOZs through           year must file Form 8997 with the           not an inclusion event under Regulations 
investment in qualified opportunity funds   taxpayer's timely filed federal income tax  section 1.1400Z2(b)‐1(c), provide the 
(QOFs). Taxpayers that invest in QOZ        return (including extensions).  An eligible following information relating to the 
property through a QOF can defer the        taxpayer is a person that is required to    transferee of the QOF investment. Enter 
recognition of certain gains. See           report the recognition of gains during the  in column (c) the taxpayer name, 
Definitions, later.                         tax year under federal income tax           taxpayer identification number, and the 
An investor in a QOF uses Form 8997         accounting principles.  If you are not      date the QOF investment was disposed 
to inform the IRS of the QOF                otherwise required to file a return, but    of. Enter in column (d) special gain code 
investments and deferred gains held at      you are an eligible taxpayer who held a     “F.”
the beginning and end of the current tax    QOF investment at any point during the 
year, as well as any capital gains          tax year, attach Form 8997 to an            Part II
deferred by investing in a QOF and QOF      appropriate return, such as Form 1040-      Complete Part II to report your capital 
investments disposed of during the          NR or Form 1120-F, with your name,          gains for the current tax year that were 
current tax year. See www.irs.gov/          address, and identification number.         deferred by investing in a QOF. 
Ozfaqs for more information and             Instructions for consolidated groups.       Complete columns (a) through (d) for 
guidance.                                   A consolidated group should include         each QOF investment. When reporting 
                                            with the group’s return a separate Form     the amount of the deferred gain, use the 
Definitions                                 8997 for each group member that held a      appropriate column (either (e) or (f)) 
Qualified opportunity fund (QOF). A         QOF investment during the tax year.         depending on whether the capital gain 
QOF is an investment vehicle organized                                                  deferred was a short-term or a long-term 
as a corporation or a partnership for the   Specific Instructions                       capital gain.
purpose of investing in QOZ property                                                    Identification requirement for 
(other than another QOF) that holds at      Name and Address                            acquisition from another taxpayer in a 
least 90% of its assets in QOZ property.                                                noninclusion transfer. If you acquired 
See the Instructions for Form 8996 for      Print or type the information in the 
more information.                           spaces provided.                            the QOF investment during the tax year 
                                                                                        in a transaction that was, in whole or in 
Qualified opportunity fund (QOF)            Taxpayer identification number. If you      part, not an inclusion event under 
investment. A QOF investment is an          are an individual, enter your social        Regulations section 1.1400Z2(b)‐1(c), 
investment of eligible gain into a QOF to   security number (SSN) or your individual    provide the following information relating 
defer recognition of the eligible gain. The taxpayer identification number (ITIN). For  to the transferor of the QOF investment. 
investment in the QOF must be in the        C corporations, partnerships, S             Enter in column (c) the taxpayer name, 
form of an equity interest in the QOF,      corporations, trusts, estates, and Indian   taxpayer identification number, and the 
which may include preferred stock or        tribes, enter the employer identification   date the QOF investment was 
partnership interests, including those      number (EIN).                               transferred to you. Enter in column (d) 
                                                                                        special gain code “F.”
with special allocations. Generally, the    Part I
investment in the QOF must have                                                         Identification requirement for transfer 
occurred within the 180-day period          Complete Part I to declare your QOF         to another taxpayer in a noninclusion 
beginning on the date the gain would be     investments held at the beginning of the    transfer. If you disposed of a QOF 
recognized for federal income tax           current tax year; for individuals, this     investment during the tax year in a 
purposes if the eligible taxpayer didn’t    would generally be January 1, 2021.         transaction that was, in whole or in part, 
elect to defer recognition of that gain. A  Complete columns (a) through (d) for        not an inclusion event under Regulations 
QOF investment is also reported on          each QOF investment. When reporting         section 1.1400Z2(b)‐1(c), provide the 
Form 8949.                                  the amount of the deferred gain, use the    following information relating to the 
                                            appropriate column (either (e) or (f))      transferee of the QOF investment. Enter 
                                            depending on whether the remaining          in column (c) the taxpayer name, 
                                            deferred capital gain in the fund was a     taxpayer identification number, and the 
                                            short-term or a long-term capital gain.     date the QOF investment was disposed 
                                                                                        of. Enter in column (d) special gain code 
                                                                                        “F.”

Form 8997 (2021)                                                                                                                     Page 4 

Waiver of Treaty Benefits on                  Part III                                      Part IV
Future Inclusions by a                        Complete Part III to report inclusion         Complete Part IV to report your QOF 
Foreign Eligible Taxpayer                     events during the current tax year for        investments held due to current year 
                                              your QOF interests. An inclusion event        capital gain deferrals and prior tax 
For tax years beginning after March           occurs if you sold or transferred your        year(s) deferrals; for individuals, this 
13, 2020. If you are a foreign eligible       QOF investment, if you received a             would generally be December 31, 2021. 
taxpayer (an eligible taxpayer that is not    distribution from the QOF, if you             Complete columns (a) through (d) for 
a U.S. person within the meaning of           declared your QOF interest worthless, if      each QOF investment. When reporting 
section 7701(a)(30) or that is treated as a   the QOF ceased to be a QOF, or if you         the amount of the deferred gain, use the 
resident of another country for purposes      or the QOF engaged in certain other           appropriate column (either (e) or (f)) 
of an applicable income tax treaty)           transactions. Some transactions are           depending on whether the deferred 
whose tax year began after March 13,          excepted from being inclusion events.         capital gain was a short-term or a long-
2020, you must, for any capital gains         See Regulations section                       term capital gain. 
that you are deferring by investing in a      1.1400Z2(b)-1(c) for a full list of inclusion If one of your QOF investments is the 
QOF, irrevocably waive any benefits           events and exceptions.                        continuation of an investment in a 
available under an applicable U.S. 
income tax convention that would              Complete columns (a) through (c) for          different QOF (for example, due to a 
exempt such gains from being subject to       each QOF investment. When reporting           reorganization), enter in column (c) the 
federal income tax at the time of             the amount of the deferred gain now           word “Formerly” and the earlier QOF's 
inclusion. A foreign eligible taxpayer        included, due to the inclusion event,         EIN.
includes, for example, any individual who     complete column (d) and report the            Identification requirement for 
is required to file Form 1040-NR, a           amount of the gain in the appropriate         acquisition from another taxpayer in a 
foreign corporation, and a foreign estate     column (either (e) or (f)) depending on       noninclusion transfer. If you acquired 
or trust.  A citizen or resident alien of the whether the previously deferred capital       the QOF investment in a transaction that 
United States who is required to file         gain was a short-term or a long-term          was, in whole or in part, not an inclusion 
Form 1040 or 1040-SR is not a foreign         capital gain. If your transaction falls       event under Regulations section 
eligible taxpayer. To waive treaty            under an exception in the regulations so      1.1400Z2(b)‐1(c), provide the following 
benefits, a foreign eligible taxpayer must    that no deferred gain is now included,        information relating to the transferor of 
check the “Yes” box provided on page 1        enter in column (c) the word “Exception”      the QOF investment. Enter in column (c) 
of Form 8997 under Waiver of Treaty           and a citation to the applicable              the taxpayer name, taxpayer 
Benefits on Future Inclusions by a            paragraph of the regulations; leave           identification number, and the date the 
Foreign Eligible Taxpayer (for Tax            columns (d)–(f) blank.                        QOF investment was transferred to you. 
Years Beginning After March 13, 2020,         Check the box in Part III if you              Enter in column (d) special gain code 
Only).                                        disposed of a QOF investment during           “F.”
Note: The waiver of treaty benefits on        the current tax year and didn’t receive a 
Form 8997 doesn’t apply to tax years          Form 1099-B from the QOF or other third       Additional Investments
beginning on or before March 13, 2020,        party reporting the disposition.              Attach and label a separate continuation 
and generally doesn’t apply to                Identification requirement for                sheet if the number of QOF investments 
partnerships. See Regulations section         acquisition from another taxpayer in a        to be reported on Part I, II, III, or IV 
1.1400Z2(a)-1(b)(11)(ix)(A)(3).               noninclusion transfer. If you acquired        exceeds the amount of lines provided. 
Written statement requirement for             the QOF investment in a transaction that      Transfer the deferred gains from the 
certain foreign eligible taxpayers. If        was, in whole or in part, not an inclusion    continuation sheet to the line on each 
you are a foreign eligible taxpayer (as       event under Regulations section               part for totals from a continuation sheet 
defined earlier) and you choose to apply      1.1400Z2(b)‐ 1(c), provide the following      and enter the amounts in the appropriate 
the section 1400Z-2 regulations in a          information relating to the transferor of     column (either (e) or (f)) depending on 
consistent manner for the portion of your     the QOF investment. Enter in column (c)       whether the deferred capital gain 
first tax year ending after December 21,      the taxpayer name, taxpayer                   invested in the fund was a short-term or 
2017, and all tax years beginning after       identification number, and the date the       a long-term capital gain.
December 21, 2017, and on or before           QOF investment was transferred to you. 
March 13, 2020 (see Regulations section       Enter in column (d) special gain code 
1.1400Z2(a)-1(g)(2)(i)), attach a written     “F.”
statement to Form 8997, signed under 
penalties of perjury, which states: “With 
respect to gain deferred pursuant to an 
election under section 1400Z-2(a), the 
below signed taxpayer irrevocably 
waives any benefits available under an 
applicable U.S. income tax convention 
that would exempt such gain from being 
subject to federal income tax at the time 
of inclusion.”