The OZ reference site written by someone who does the deals.
Opportunity Zones are one of the most powerful structures in the U.S. tax code. They are also one of the most misunderstood. OZ HQ exists to fix that. This is an expert-edited reference site that explains how the program actually works, where the rules changed under OZ 2.0, and what matters most during the 2026-to-2027 transition, built by an operator who has structured and deployed OZ capital across 25+ real estate projects.
Accurate. Specific. Updated as guidance evolves.
The Most Important Decision in OZ Right Now
The date you fund your QOF determines whether you get OZ 1.0 rules or OZ 2.0 rules. Not the date you realized the gain. A 2026 gain funded into a QOF in 2026 gets zero basis step-up and a tax bill due April 2027. The same gain funded in January 2027 gets a rolling five-year deferral and a 10% basis step-up.
For most investors with flexibility in their 180-day window, waiting until January 1, 2027 is the mathematically superior choice. Read the full comparison
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 explainer
How 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 works
What is the 10-year benefit? If an investor holds a qualifying OZ investment for at least 10 years, all post-investment appreciation is excluded from federal capital gains tax. Depreciation recapture is also eliminated, not deferred, at exit through a fair market value basis step-up. Tax benefits explained
What 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 explained
How 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
Featured Guides
OZ 1.0 vs. OZ 2.0: The Complete Transition Guide
The most important page on this site for anyone making an OZ decision in 2026 or 2027. Covers the July 6, 2026 cutoff, the K-1 timing bridge, the two-year dual-map overlap, and the zero vs. 10% basis step-up comparison. Read the guide
The 180-Day Rule: Complete Guide
The single rule that causes the most lost OZ opportunities. Covers direct sales, K-1 partnership elections, crypto per-lot rules, and the March 15 extended window. Read the guide
How to Evaluate an OZ Fund: 9 Questions
What sophisticated investors ask before committing capital to a 10-year structure. Written from the operator side of the table. Read the guide
Bishop Ridge: A Neighborhood Case Study
How concentrated OZ investment transformed a blighted Dallas neighborhood into a 1,000-unit micro-community across 25+ projects. Read the case study
For Specific Audiences
Investors — Understand the tax benefits, evaluate timing decisions, and learn how to assess fund sponsors from someone who builds and operates OZ projects. Investor guide
Advisors and CPAs — Coming Soon — Practical answers on timing, reporting, structuring, and the questions clients will ask in 2026 and 2027. Advisor guide
Journalists and researchers — Data-backed explainers, policy context, and primary-source summaries. Policy and data
State and local officials — Zone designation strategy, tract selection, and the 2027 map cycle. Designation guide