Does Any OZ 2.0 Investor Get the Ten-Year Benefit?
OZ 2.0 zones expire December 31, 2036, before any investor can reach the ten-year mark, and no current law or guidance says what happens then.
The Opportunity Zone incentive was made permanent by the One Big Beautiful Bill Act and rebuilt around a new designation round running 2027 through 2036. These pieces cover the transition from the 2018 zones, the nomination process and the published tract lists, and the drafting that sponsors are doing now to carry projects across the seam.
5 pieces
OZ 2.0 zones expire December 31, 2036, before any investor can reach the ten-year mark, and no current law or guidance says what happens then.
Kansas has not published its OZ 2.0 nominations. An open records request produced 96 tract identifiers combining the 2018 designations with the new round. Here are the 53 nominated tracts, mapped.
What Notice 2026-40, the IRS's first OZ 2.0 transitional guidance, means for developers raising and deploying capital across the 2027 seam.
Sponsor-side insert provisions for a qualified opportunity zone business operating agreement that takes OZ 1.0 capital in 2026 and OZ 2.0 capital in 2027: vintage tracking, qualification by vintage, reporting, and protective covenants.
Where Opportunity Zones stand in 2026: the 1.0 inclusion deadline, the 50% rural substantial improvement threshold, and what changes when OZ 2.0 goes live January 1, 2027.
The Developer's Brief
Occasional dispatches on deal structure, entitlements, and the quiet patterns that move large projects. No filler.
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