Executing A Location-Driven OZ Strategy, With Alicia Miller

How does a prime neighborhood drive an Opportunity Zone project’s success? Alicia Miller of Black Salmon joins the show to discuss her firm’s “location-first” strategy.

Alicia shares details on Black Salmon’s new multifamily development in downtown St. Petersburg and a flagship retail project in Miami’s Design District, and explains how a single-asset holdco structure keeps investors on track for the 10-year tax-free exit.

Guest: Alicia Miller, Black Salmon

About The Opportunity Zones Podcast

Hosted by OpportunityZones.com founder Jimmy Atkinson, The Opportunity Zones Podcast features guest interviews from fund managers, advisors, policymakers, tax professionals, and other foremost experts in the Opportunity Zones industry.

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Episode Summary

In this episode of The Opportunity Zones Podcast, host Jimmy Atkinson speaks with Alicia Miller, head of U.S. capital markets at Black Salmon, about the firm’s two new Opportunity Zone developments, the current investor appetite for OZ deals, and how the program has evolved since its 2018 launch.

Guest Introduction: Alicia Miller

Alicia leads U.S. investor relations for Black Salmon’s $2 billion real-estate platform. Her background spans capital raising for family offices and high-net-worth individuals after an unexpected shift from musical-theater studies to real-estate finance. She joined Black Salmon in late 2024, shortly after the company received institutional backing from Latin American financial institution LarrainVial, and now focuses on growing the firm’s U.S. capital base.

Black Salmon’s Opportunity Zone Strategy

  • Two active QOZ developments: a multifamily project in Downtown Saint Petersburg, Florida and a three-story retail project in Miami’s Design District.
  • Previous QOZ success: a fully leased multifamily project in Miami’s Wynwood neighborhood, developed with Bridge Investment Group.
  • Core thesis: acquire sites in “the best neighborhoods at the entry point for Class A,” letting location drive returns; QOZ status is treated as an added benefit, not the sole reason to build.

Investor Landscape and Capital Sources

  • Historic strength with Latin American investors, now expanding to U.S. capital.
  • Primary segments interested in QOZ deals:
    • Family offices focused on capital-gains planning.
    • High Net Worth investors with patient capital.
    • RIAs that function like multifamily offices and seek alternatives beyond stocks, bonds, ETFs, and mutual funds.
  • Institutional investors are largely agnostic to capital-gains treatment and therefore less active in QOZs.

Alicia Miller’s Career Path

  • Started in real estate after meeting her first mentor in Denver; moved directly into capital development.
  • Worked for several real-estate investment firms before meeting Black Salmon’s principals in Miami.
  • Drawn to Black Salmon by the firm’s growth, Latin American relationships, and Wynwood QOZ success; joined to build out U.S. investor relations.

Evolving Opportunity Zone Market Trends

  • Early enthusiasm (2018-2020) featured large multi-asset QOZ funds; many struggled to place capital into quality assets on time.
  • Investor appetite has tapered because:
    • Higher interest rates slowed real-estate exits, M&A, venture-capital realizations, and stock sales—reducing new capital-gains events.
    • Annual step-up benefits expired, and the deferral period now ends 12/31/2026.
    • Some early deals exited in year 4, preventing investors from realizing the full 10-year benefit.
  • Greater education today helps investors focus on single high-quality projects instead of blind-pool strategies.

Multi-Asset Funds vs Direct OZ Projects

  • Multi-asset funds can diversify risk but may leave capital idle if quality OZ sites are scarce.
  • Direct projects offer clarity on location, timeline, and underwriting.
  • Black Salmon organizes each deal through a single-asset QOZ fund that invests into a holding company. If a project exits early, the proceeds can roll into a new QOZ project without resetting the 10-year clock.

Structuring Considerations and Holdco Approach

  • Funds flow from investor → QOZ fund → QOZB holding company → QOZ property.
  • The two-tier structure preserves the investor’s 10-year holding period even if the first asset sells in year 4 or year 5; capital is redeployed into another qualifying project instead of being distributed.

Opportunity Zones vs 1031 Exchanges and TICs

  • 1031/TIC requires reinvesting principal and gain into real estate only; benefit is realized through “swap-till-you-drop.”
  • Opportunity zones accept gains from any asset class (real estate, stocks, business sale, collectibles, crypto) and allow the investor to keep the original principal.
  • QOZ investors achieve full tax-free appreciation after 10 years—without having to pass the asset to heirs.
  • A 1031 cannot be rolled directly into a QOZ; only the capital-gains portion qualifies.

Current Black Salmon OZ Projects

Saint Petersburg, FL – Multifamily with Retail

  • Downtown location near the planned Hines Tropicana Stadium.
  • Class A apartments with sauna, steam, cold-plunge, dog-wash, and indoor-outdoor amenities; smaller unit sizes reflect Florida’s outdoor lifestyle.
  • Ground-floor mixed-use retail to enhance walkability.

Miami Design District – Corner-Lot Flagship Retail

  • Acquired in 2017 on a prime corner; surrounded by luxury designer flagships and high per-square-foot rents.
  • Plans call for a three-story retail building; tenant selection timed to capture continued rent growth.

Legislative Outlook for OZ 2.0

  • As of June 24 2025, Senate Finance Committee language would:
    • Make opportunity zones permanent.
    • Replace the current map with a new set of zones effective 2027.
  • Many thriving areas—such as Downtown Saint Petersburg and the Miami Design District—may not qualify under the new map, making this “possibly investors’ last opportunity” to access these locations through the existing program.

Common Misconceptions About Opportunity Zones

  • Misbelief that QOZs are confined to undesirable neighborhoods.
  • Assumption that QOZ assets are inherently inferior.
  • Reality: some designated tracts (e.g., Design District) have already transformed into top-tier markets, demonstrating the program’s impact.
  • Successful QOZ investing still begins with rigorous underwriting; the tax benefit should reinforce, not replace, strong fundamentals.