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On July 4, 2025, President Trump signed Public Law No: 119-21, the One Big Beautiful Bill Act (the Act) into law. Among other provisions, the Act permanently extends the opportunity zone (OZ) program with certain modifications and enhancements. Without these modifications, investments in OZs after December 31, 2026 would have no longer been eligible for OZ tax benefits.
The revisions to the OZ program aim to address some of the issues raised by policymakers by narrowing the scope of census tracts that are eligible to be nominated as OZs, as well as providing increased tax benefits for investment in rural areas. The Act also introduces new information reporting requirements for qualified opportunity funds (QOFs) and qualified opportunity zone businesses (QOZBs), along with penalties for failure to comply with these new requirements.
Business leaders should evaluate the effect of the revisions to and expansion of the OZ program in the Act to determine how they affect current and future projects. Assessing the effects of the tax law changes will need to include not only the federal tax changes but should take into account any state tax, tax accounting and other related implications.
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