Tax Insight

IRS provides listing of eligible Qualified Opportunity Zone census tracts

Insight
5 minute read
April 09, 2026

What happened?

Treasury and the Internal Revenue Service released Rev. Proc. 2026-14 on April 6, 2026 to provide guidance to Chief Executive Officers of the 50 states, the District of Columbia, Puerto Rico, and all other US territories regarding the procedure for nominating population census tracts to be designated as qualified opportunity zones (QOZs). In addition to guidance on the overall nomination process, Rev. Proc. 2026-14 includes as an appendix a list of eligible census tracts based on the 2020-2024 American Community Survey (ACS) 5-year and the 2020 Decennial Census of Island Areas (DECIA) data sets from the Bureau of the Census.

Why is it important?

The QOZ tax incentive, first enacted as part of the 2017 Tax Cuts and Jobs Act (TCJA), was made permanent as part of the One Big Beautiful Bill Act (OBBBA). OBBBA provided for new QOZ designations every ten years and made several amendments to the TCJA-enacted tax incentive, including increased restrictions regarding the eligibility requirements for a census tract to be designated as a QOZ. The first “decennial determination date” is set to occur on July 1, 2026, with new designations coming into effect on January 1, 2027. Many census tracts that were designated QOZs as part of the TCJA-enacted QOZ tax incentive may be ineligible for designation in this new round due to the tightened eligibility requirements enacted under the OBBBA.

Actions to consider

Investors and sponsors of qualified opportunity funds (QOFs) and qualified opportunity zone businesses (QOZBs) should analyze the newly published list of eligible census tracts, and work with their state and local governments to nominate tracts for designation. It is important to note that, to the extent a tract is not included in the published list, additional nominations may be considered if accompanied by a detailed analysis demonstrating that the nominated tract satisfies the QOZ eligibility requirements.