For law firms
You form the fund and write the working capital plan. Whether anyone tracks spending against it is out of your hands the day the engagement closes.
Refer at formation and the reporting calendar exists before the first dollar moves.
Actual spend measured against the schedule you wrote, month by month.
No software for your associates, and no compliance questions landing on your desk in January.
What happens to your drafting
The plan you drafted is loaded once, with its dates and its targets. Every outlay after that is measured against it, so the safe harbor you designed is evidenced rather than assumed.
Riverline QOZB One
Adopted March 2026 · 31 month schedule
Drafted by ____________, counsel of record
How a referral works
The whole ask is a name and an email while the formation file is still open. Everything downstream happens between us and the sponsor.
Send the sponsor's name while the entity documents are still on your desk. That is the whole referral.
Your firm · One emailThe written plan, its targets, and its 31 month schedule go in exactly as you drafted them.
Your firm · NothingEvery outlay is measured against the schedule, with the source document held beside the figure.
Your firm · NothingBoth asset tests computed and a Form 8996 package assembled, without anyone calling you about it.
Your firm · NothingThree of four stages ask nothing of your firm
Two ways to refer
The client gets the same thing either way. What changes is how much you see afterwards and whether you want to.
We never approach a client you introduced about anything other than the file you sent.
Why this reaches you at all
The safe harbor is not granted by the drafting. It is earned by the spending matching the schedule, over 31 months, with records to show it. When that does not happen the document has your name on it.
Once capital is deployed nobody wants to hear about reporting. At closing they are still listening.
Sponsors of the size that hire outside counsel are running the year on spreadsheets. That is who the reporting was written for.
When a checkpoint is missed, the call goes to whoever drafted the plan first and asks questions later.
Neither the taxpayers nor their accountants knew Form 8996 existed.
Treasury Inspector General for Tax Administration
For law firms
You form the fund and write the working capital plan. Whether anyone tracks spending against it is out of your hands the day the engagement closes.
Refer at formation and the reporting calendar exists before the first dollar moves.
Actual spend measured against the schedule you wrote, month by month.
No software for your associates, and no compliance questions landing on your desk in January.
