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Opportunity Zones (OZ 2.0) — now permanent

The One Big Beautiful Bill Act (signed July 4, 2025) made the QOZ tax incentive permanent and added enhancements. Invest capital gains into a Qualified Opportunity Fund within 180 days to defer the gain; hold 10+ years to make all QOF appreciation tax-free. First new round of QOZ designations takes effect Jan 1, 2027.

How it works in three benefits: (1) deferral of the original capital gain you rolled into the QOF; (2) under OBBB, the deferral end-date is rolling and the program is permanent; (3) if you hold the QOF for 10+ years, your basis steps up to fair market value at sale — meaning the appreciation on the QOF investment itself is entirely tax-free.

OBBB also created "Rural QROFs" with enhanced incentives: 30% basis step-up at five years (vs. 10% for non-rural), 50% substantial improvement threshold (vs. 100%). For investors with rural-aligned theses (manufactured housing, agricultural infrastructure, small-town multifamily), this materially changes the math.

Risks: QOFs are securities, with sponsor risk and reduced liquidity. The OZ designation list itself is being refreshed — properties currently in OZs may not be in the next round. Underwriting matters; the tax benefit can't save a bad deal.

#opportunity zone#QOF#OBBB

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