Opportunity Zones 2.0: Unlocking Value for Family Offices

  • Insight
  • April 2026
Jonathan  Flack

Jonathan Flack

Global & US Family Office & Family Business Leader, PwC US

Steven Kennedy

Steven Kennedy

Real Estate Partner, PwC US

Opportunity zones continue to develop as a strategic tool for family offices focused on long-term wealth preservation and purposeful investing. In this episode of PwC’s Financial Services Tax Audiocast series, Jonathan Flack, PwC’s Global and US Family Office Leader, and Steve Kennedy, PwC’s National Opportunity Zone Specialist, discuss the latest changes under Opportunity Zones 2.0 — including new timing flexibility, expanded benefits, tighter zone designations, and increased compliance requirements — and highlight the importance of early planning and careful structuring.


Key takeaways

  • Opportunity zones remain a compelling option for family offices seeking to defer and reduce capital gains while supporting communities connected to their legacy.
  • Opportunity Zones 2.0 (OZ 2.0) introduces a rolling five-year deferral window, replacing the prior fixed deadline, allowing greater investment flexibility.
  • Changes include enhanced benefits for rural zones, revised income thresholds for zone eligibility, and new reporting requirements that add complexity but improve transparency.
  • The shift toward OZ 2.0 brings critical compliance and risk management considerations, from reinvestment timing to project completion milestones.
  • Proper structuring from the outset is vital; retroactive fixes are difficult and risky.
  • Coordinating across advisors is essential, given the intersection of tax, real estate, operational, and reporting complexities.
  • For family offices with upcoming liquidity events, early evaluation and modeling of opportunity zone investments are strongly recommended.  

Segmented topics with timestamps:

  • 0:17 – Relevance of opportunity zones for family offices
  • 1:01 – Core incentives and benefits of opportunity zones
  • 2:24 – Opportunity zones as a tool for purpose-driven investing and community impact
  • 2:49 – Key updates under OZ 2.0, including rolling deferral window and enhanced rural benefits
  • 3:42 – Changes to designation criteria and impact on site selection
  • 4:26 – Increased reporting requirements and implications for compliance
  • 5:00 – Risk management and critical deadlines to maintain tax benefits
  • 5:39 – Importance of structuring investments properly from day one
  • 6:08 – Recap of OZ 2.0 highlights and family office planning priorities
  • 7:05 – Next steps

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Jonathan  Flack

Jonathan Flack

Global & US Family Office & Family Business Leader, PwC US

Steven Kennedy

Steven Kennedy

Real Estate Partner, PwC US

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