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FEATURED ARTICLE
Opportunity Zone 2.0: The Map Is Out, and the Clock Is Almost Up
In April, the IRS and Treasury released Revenue Procedure 2026-12 — the official playbook, and the official map, for nominating the next generation of Opportunity Zones.
The guidance names by census tract all 25,332 communities eligible for designation in 2027. One in three is fully rural, and rural fund investors now receive a 30% basis step-up after five years, triple the standard 10%, plus a substantial improvement threshold cut to 50%.
But the map is shrinking. OZ 1.0 produced 8,764 designated zones. Industry estimates put OZ 2.0 at roughly 6,300 to 6,500 — about 25% fewer — with boundaries drawn from the 2020 decennial census and locked from January 1, 2027 through December 31, 2036. No redrawing. No splitting. No adjustments of any kind.
Governors have until September 28, 2026 to submit nominations, with one possible 30-day extension. And if you hold Puerto Rico exposure in your OZ portfolio, your 10-year clock ends a full year earlier than you may be assuming.
Fewer zones will not mean fewer opportunities — but the best deals in the best locations will draw more competition, and early movers hold a real advantage.
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