Opportunity Zones have been one of the most compelling tax incentives in modern economic policy since their creation in 2017. They were designed to channel capital into income-limited census tracts by offering tax advantages that reward long-term investment. Under the One Big Beautiful Bill, the Opportunity Zone program has not only been renewed but expanded. A new Opportunity Zone 2.0 framework will take effect in 2027, with new designations and enhanced benefits for rural communities.

For fund managers, developers, and private equity sponsors, Opportunity Zones remain one of the few areas in the tax code where gains can be permanently eliminated. Understanding the changes and preparing now will be critical for capital raising, fund structuring, and long-term planning.

This blog outlines what remains the same, what has changed, and how fund managers can strategically position themselves ahead of the Opportunity Zone 2.0 rollout.

What Opportunity Zones Were Designed To Do

The Opportunity Zone program was originally created to encourage investors to redeploy unrealized capital gains into economically distressed areas. The basic structure has remained consistent:

• Investors sell appreciated assets such as stock, real estate, or business interests.

• Capital gains are rolled into a Qualified Opportunity Fund.

• Tax on the original gain is deferred until a future recognition date.

• If the Opportunity Zone investment is held for at least ten years, all new gains inside the zone are eliminated.

The elimination of tax on new gains is one of the strongest incentives in the IRC. It applies to all appreciation and includes recapture, which is rare. For long-term investors, the after-tax return advantage can be substantial.

Opportunity Zones 2.0: What Has Changed

The One Big Beautiful Bill extends the program permanently but introduces important updates.

1. New Designations Across the Country:
Governors across all states will designate a new set of Opportunity Zones by next summer. These new zones will reflect updated census data, current economic conditions, and areas that have not previously benefited from large capital inflows.

For fund managers, this creates new regions of potential investment activity and a fresh wave of qualified projects.

2. Opportunity Zone 2.0 Launches in 2027:
The revised program begins in 2027, giving fund managers time to prepare, structure funds, identify projects, and educate investors.

This timeline allows sponsors to underwrite long-term opportunities and build fundraising strategies that align with the program’s updated benefits.

3. Expanded Incentives for Rural Areas:
The bill includes enhanced tax advantages for rural Opportunity Zones. These may include increased basis step-ups, expedited designation processes, or additional incentives for development in areas that lack access to private capital.

This aligns with the broader policy theme of supporting rural America and returning capital to communities that have historically been under-invested.

What Has Not Changed

The core economic engine of Opportunity Zones remains intact.

• Gains can still be deferred upon reinvestment.

• Long-term gains from Opportunity Zone investments can still be eliminated after a ten-year hold.

• Qualified Opportunity Funds remain the primary vehicle for OZ investments.

• Investors can still combine Opportunity Zone strategy with bonus depreciation and cost segregation to improve early-year tax outcomes.

For fund managers, this means that the fundamental selling point of Opportunity Zones is unchanged: they remain one of the most tax-efficient long-term investment tools available.

Why Opportunity Zones Still Matter for Funds

Opportunity Zones provide several advantages that fund managers should leverage:

1. Long-Term Gain Elimination:
This remains the strongest incentive. No other part of the tax code offers the same combination of deferral, basis step-up, and complete elimination of tax on new gains.

2. Strategic Capital Raising:
Many investors have built-in demand for tax-efficient investments, particularly coming out of major liquidity events. The updated program creates a new entry point for those investors.

3. Enhanced Project Economics:
With bonus depreciation made permanent, projects placed in service after January 19, 2025, can yield substantial first-year losses, increasing early-year cash flow and investor tax benefits.

4. Improved After-Tax IRR:
Funds that fully integrate Opportunity Zone incentives can produce higher after-tax returns, which strengthens investor confidence and accelerates fundraising.

5. Clearer Long-Term Planning Environment:
By making the program permanent, the bill removes uncertainty and gives fund managers visibility into long-horizon projects.

How Fund Managers Should Prepare for Opportunity Zones 2.0

The 2027 launch of Opportunity Zone 2.0 creates a planning window. Fund managers should use this period to:

1. Identify Target Markets Early:
Review census data, demographic shifts, local economic development activity, and gubernatorial proposals to anticipate which areas are likely to be designated.

2. Build or Expand Qualified Opportunity Funds:
Sponsors may want to create parallel funds or series structures designed to take advantage of new zones as soon as they are announced.

3. Underwrite Long-Term Projects:
Because Opportunity Zone tax elimination applies only after a ten-year hold, the program is best suited for projects with long development timelines.

4. Coordinate Tax Planning With Depreciation Strategy:
Bonus depreciation, cost segregation, and opportunity zone benefits compound each other. Integrating these strategies strengthens both early-year and long-term tax outcomes.

5. Educate Investors In Advance:
Capital raising is more efficient when investors understand the program before a transaction is launched. Opportunity Zones attract investors with unrealized gains, and advanced education can help convert those conversations into commitments.

Common Misconceptions About Opportunity Zones

Throughout the history of the program, several misconceptions have persisted:

• Opportunity Zones are not exclusively for multifamily development. Industrial, hospitality, mixed-use, and certain business operations all qualify.

• Opportunity Zone benefits do not require a 1031 exchange. They are independent.

• Capital gains from the sale of stocks, businesses, or other assets can qualify, not just real estate.

• Investors do not need to eliminate tax on the original gain to benefit. The elimination of new gains often provides a greater long-term advantage.

Clearing up these misconceptions helps fund managers raise capital more effectively.

Why Opportunity Zones Are Even More Attractive Now

The renewal and enhancement of the program give fund managers several advantages:

• Greater certainty for long-term planning

• A fresh wave of qualifying census tracts

• New rural incentives

• Integration with permanent bonus depreciation

• A stronger political and regulatory foundation

Opportunity Zones 2.0 will create another cycle of investment activity. Fund managers who prepare now will be positioned to capitalize on these opportunities when the new designations are released.

Final Takeaway

Opportunity Zones 2.0 represent a renewed commitment to channeling capital into underserved areas while providing investors and fund managers with one of the strongest tax incentives available. With the core structure preserved and new benefits introduced, the next phase of Opportunity Zones will create significant opportunities for long-term investment, development, and tax optimization.

Fund managers who start preparing today will be ahead of the curve when the next round of designations goes live.

Book Your Tax Strategy Call with James

If you want to understand how the new Opportunity Zone rules will affect your fund strategy, capital raising plans, or long-term tax outcomes, now is the time to take action. There is still time to review your structure, refine your approach, and plan for the coming Opportunity Zone 2.0 designations. Once the year closes, these opportunities are gone.

Schedule Your Tax Strategy Session Now