The OZ reference site written by someone who does the deals.
Opportunity Zones are a complex structure in the U.S. tax code and one of the most misunderstood. OZ HQ is an expert-edited reference that separates enacted law, final regulations, announced guidance, and operator judgment.
The most important decision in OZ
Timing and qualification rules determine which OZ provisions may apply.
Not the date you realized the gain. Direct gains have a fact-specific 180-day period, and pass-through owners may have different start-date alternatives. The July 6, 2026 date is only a raw direct-gain threshold.
Notice 2026-40 section 4.02 is announced transition guidance, not final regulations. Compare timing, qualification, liquidity, and investment facts before acting.
Read the full comparisonGetting Started
Five questions most people ask first.
What is an Opportunity Zone?
A designated census tract where investors can receive federal tax benefits by reinvesting eligible capital gains through a Qualified Opportunity Fund (QOF) within 180 days of realizing the gain.
Full explainerHow does the tax deferral work?
The original capital gains tax is deferred until the end of a statutory deferral period. Under OZ 1.0, that deadline is December 31, 2026, with tax due in April 2027. Under OZ 2.0, gains invested on or after January 1, 2027 are deferred for a rolling five years from the investment date.
How deferral worksWhat is the 10-year benefit?
After the applicable ten-year hold, the final regulations provide a QOF-interest-sale basis adjustment and, for eligible partnership or S corporation structures, an asset-sale election. The result depends on the election, assets, basis, liabilities, and other requirements.
Tax benefits explainedWhat changed under OZ 2.0?
The One Big Beautiful Bill Act (OBBBA), enacted in 2025, made the OZ program permanent, introduced a 10% basis step-up for standard investments and a 30% basis step-up for rural zones, tightened zone eligibility criteria, and created new mandatory reporting requirements.
OBBBA changes explainedHow do I know if a fund is well-structured?
Start by asking whether the deal works on a pre-tax basis. Then ask about the capital stack, the sponsor's vertical integration, GP co-investment, and whether the fund has identified assets before raising capital.
Due diligence framework
“I built this site to make the rules and practical questions easier to find and evaluate.”About the editor
Featured Guides
The transition guide
OZ 1.0 vs. OZ 2.0
A sourced guide to the raw July 6 direct-gain threshold, pass-through alternatives, and Notice 2026-40 transition guidance.
Read the guideComplete guide
The 180-Day Rule
Day-one counting for direct gains and the actual entity dates that may apply to partnership or S corporation owners.
Read the guideNine questions
How to Evaluate an OZ Fund
What sophisticated investors ask before committing capital to a 10-year structure. Written from the operator side of the table.
Read the guideA neighborhood case study
Bishop Ridge
A disclosed operator case study about concentrated investment in a Dallas neighborhood.
Read the case studyChoose Your Path
Investors
Tax benefits, timing decisions, evaluating sponsors.
Investor guideJournalists & Researchers
Data-backed explainers, policy context, primary-source summaries.
Policy & dataAdvisors
A linked workflow for gain facts, timing, property, liquidity, reporting, and exits.
Advisor guideState & Local Officials
Zone designation strategy, tract selection, the 2027 map cycle.
Designation guide