Indiana Dunes Club

Whisper Dunes cleared at $235K–$399K per lot with $475–$525/sf finished construction — and no Lake Kai frontage. Beachwalk’s 200-home rental resort has more than doubled in value over twenty years. Indiana Dunes Club draws from both, on the same dunes, with deeded Lake Kai frontage, an All-Seasons Resort Club, and 71 fee-simple homesites. Beachwalk and Whisper Dunes set the floor — not the ceiling.

Target budget of $1M entitlements + $4M infrastructure + $2M amenities = $7M horizontal, or ~$98.6K/lot. At a $550/sf blended sellout, the project nets ~$64.6M pre-land on a 39.0% margin. Every $500K of site-development overrun costs ~30 bps of margin; every $25/sf of blended pricing lift adds ~$7.5M to net.

An Opportunity Zone (OZ) is a federally designated census tract where the IRS grants special tax treatment to investors who deploy realized capital gains into a qualifying business or real estate project inside the tract. Investors don't put in fresh cash — they roll a taxable gain from a prior asset sale (stock, business, real estate) into a Qualified Opportunity Fund (QOF), which then invests in a Qualified Opportunity Zone Business (QOZB) that owns and operates the project.

Indiana Dunes Club sits in Tract 430 (Michigan City, LaPorte County, IN) — verified as a designated Qualified Opportunity Zone under the permanent OZ 2.0 program enacted by the One Big Beautiful Bill Act (July 2025) and effective January 2027.

Durability of this tax treatment

A fair investor question: can Congress change the rules on me mid-hold? The honest answer below.

OBBBA made OZ a permanent part of the tax code — no sunset date, no risk that the whole program disappears while you're mid-hold. Under the prior regime, the entire OZ incentive was scheduled to expire December 31, 2026; OBBBA repealed that sunset and wrote OZ into the Internal Revenue Code as a standing program with rolling ten-year zone redesignations.

Your 10-year exclusion is a codified statutory election you make in Year 1 — filed on Form 8949 when you first roll the gain, and locked in under IRC §1400Z-2(c). It is not a discretionary program you have to re-qualify for annually.

Congress has never retroactively undone a vested OZ benefit for investors already in the program. In practice, when Congress changes a tax incentive it grandfathers taxpayers who invested in reliance on the prior law — OBBBA itself did exactly this by preserving OZ 1.0 rules for pre-2027 investments and applying the new 2.0 rules only to investments made January 1, 2027 and later. That's the pattern investors historically get.

The honest limit: that's about as strong a protection as US tax law offers — but it is not a constitutional guarantee. Congress retains the power to amend the tax code at any time, and no OZ statute contains an anti-retroactivity clause. This is the same underlying risk that applies to every long-hold tax incentive (1031 exchanges, low-income housing credits, R&D credits, municipal bond exemption). Historically low probability, but not zero.

• It does not shelter the Year-5 deferred-gain tax with cost-segregation depreciation. The Year-5 tax is on the original capital gain from a prior asset — the project's depreciation offsets project income, not that legacy gain.
• It does not shelter ordinary income by default. Depreciation is passive and offsets passive income — unless the short-term-rental 7-day average-stay test is met and the investor materially participates, which reclassifies losses as non-passive.
• It does not waive state tax. Federal exclusion is automatic; state conformity depends on your state of residence.
• It does not eliminate underwriting risk — rents, exit cap, construction costs, hold period. OZ is a tax overlay; the deal still has to work on its own economics.
• It does not allow rollover of gain from a related-party sale, ordinary income, or gains realized outside the 180-day window.

Three stacking tax benefits, one election

Sources: IRC §1400Z-2 as amended by One Big Beautiful Bill Act of 2025 (permanent OZ 2.0 program, effective Jan 1, 2027). Indiana nominated its 2027–2036 OZ tracts on Sept 25, 2026, including Tract 430 (rural); designation is pending U.S. Treasury certification and will be confirmed before deal close.

One unit = $100,000 of capital gains

Every OZ investor scales in units of $100K. The math below is calculated per unit; multiply by however many units match the investor's gain size.

Most large OZ investors will hold both

Indiana Dunes Club qualifies under the original-use test because it is ground-up construction of new buildings that have never before been placed in service in the Opportunity Zone. There is no requirement to double the basis of any existing structure and no requirement to change the use of the property.

Indiana Dunes Club qualifies as QOZBP because the buildings we construct are new to the Opportunity Zone — the original-use test. This is the standard qualification path for ground-up OZ development and does not require doubling the basis of any existing structure or changing the use of the land. Investors’ tax counsel should review the Path 1 election in the executable QOF and QOZB documents at term-sheet stage.