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Opportunity Zone program made permanent and new rural funds added, IRS panel says
Summary
IRS presenters said the Qualified Opportunity Zone program is now permanent under Public Law 119‑21, introduces a new qualified rural opportunity fund category, and will allow rolling 10‑year designations and a permanent 10% basis step‑up beginning in 2027.
During the webinar Richard Furlong summarized changes to the Qualified Opportunity Zone (QOZ) program under Public Law 119‑21.
Furlong said the program is now permanent and will permit successive 10‑year zone designations by states and territories; beginning in 2027 the program will allow a rolling 10‑year designation schedule and a rolling gain‑deferral rule. He also said the law creates a new category, the qualified rural opportunity fund, designed to direct capital to certain rural areas, and cited Notice 2025‑50 (Sept. 30) that clarifies the definition and application of rural area rules and substantial improvement tests.
The presenter described that QOZ investments continue to be subject to strict asset tests (90% asset test) and reporting requirements (Forms 8996 and 8997) and warned that Treasury and IRS expect to issue further regulations to prevent abuse and set reinvestment and certification rules.
Tax practitioners and investors should review Notice 2025‑50 and the IRS OBBB landing page for forthcoming guidance that will provide technical detail on the rural fund category, reporting requirements and the rolling designation mechanics.
