The Opportunity Zone program is entering a new phase. With the passage of the One Big Beautiful Bill Act, Opportunity Zones are now a permanent part of the U.S. tax code. This change provides long-term clarity, and the transition from the original Opportunity Zone framework to the permanent structure will occur over several years. Understanding the timeline, regulatory updates, and anticipated changes in 2027 is important for those studying Opportunity Zones.
From a Fixed Deadline to a Permanent Opportunity Zone Structure
The original Opportunity Zone program, created under the 2017 Tax Cuts and Jobs Act, was based on a fixed timeline. Deferred capital gains were required to be recognized by December 31, 2026, and original zone designations were scheduled to expire shortly thereafter.
The One Big Beautiful Bill Act establishes Opportunity Zones as a permanent part of the tax code. It introduces recurring ten-year census tract designation cycles and updated regulatory guidance. While the original framework remains in effect through 2026, a new structure—sometimes called Opportunity Zones 2.0—is expected to begin in 2027.
Key Dates for the Opportunity Zone Transition
The transition to the permanent Opportunity Zone framework is expected to follow these dates:
- July 1, 2026: State governors may begin nominating new census tracts for Opportunity Zone designation.
- December 2026: The U.S. Treasury is expected to certify and finalize the list of newly designated Opportunity Zone tracts.
- January 1, 2027: The permanent Opportunity Zone framework is expected to take effect, with new designations and updated rules applying to activities occurring on or after this date.
These steps provide continuity between the original program and the permanent framework.
The Overlap Period
From January 1, 2027, through December 31, 2028:
- Original Opportunity Zone designations are expected to remain valid
- Newly designated Opportunity Zones will also be recognized
- Both sets of zones will coexist, allowing activities to follow the rules associated with either the original or new framework
Sunset of Original Opportunity Zones
Original Opportunity Zone designations are scheduled to sunset on December 31, 2028. Beginning January 1, 2029:
- Only newly designated Opportunity Zones will remain eligible
- Opportunity Zones will continue under ten-year designation cycles
How Opportunity Zones Are Expected to Function
With the permanent framework, Opportunity Zones are expected to provide a consistent and long-term structure. The program is designed to support:
- Multi-year planning within the tax code framework
- Coordination with the local community and economic development initiatives
- Ongoing census tract designation cycles for future updates
Why Understanding the 2027 Opportunity Zone Framework Matters
The next phase of Opportunity Zones coincides with ongoing discussions around housing and urban development. With new designations and updated rules, Opportunity Zones will remain an important element of U.S. tax law. Tracking program timelines, Treasury certifications, and regulatory guidance can help students, researchers, and professionals understand how the program evolves.
For more educational resources about Opportunity Zones, visit our [Opportunity Zone fund page] (for educational purposes only).
Important Disclosures
The contents of this communication: (i) do not constitute an offer of securities or a solicitation of an offer to buy securities, (ii) offers can be made only by the confidential Private Placement Memorandum (the “PPM”) which is available upon request, (iii) do not and cannot replace the PPM and is qualified in its entirety by the PPM, and (iv) may not be relied upon in making an investment decision related to any investment offering by an issuer, or any affiliate, or partner thereof ("Issuer").
All potential investors must read the PPM and no person may invest without acknowledging receipt and complete review of the PPM.
With respect to any performance levels outlined herein, these do not constitute a promise of performance, nor is there any assurance that the investment objectives of any program will be attained. All investments carry the risk of loss of some or all of the principal invested. Assumptions are more fully outlined in the Offering Documents/ PPM for the respective offering. Consult the PPM for investment conditions, risk factors, minimum requirements, fees and expenses and other pertinent information with respect to any investment.
These investment opportunities have not been registered under the Securities Act of 1933 and are being offered pursuant to an exemption therefrom and from applicable state securities laws. All offerings are intended only for accredited investors unless otherwise specified.
Past performance are no guarantee of future results. All information is subject to change. You should always consult a tax professional prior to investing. Investment offerings and investment decisions may only be made on the basis of a confidential private placement memorandum issued by Issuer, or one of its partner/issuers. Issuer does not warrant the accuracy or completeness of the information contained herein. Thank you for your cooperation.
Real Estate Risk Disclosure:
- There is no guarantee that any strategy will be successful or achieve investment objectives including, among other things, profits, distributions, tax benefits, exit strategy, etc.;
- Potential for property value loss – All real estate investments have the potential to lose value during the life of the investments;
- Change of tax status – The income stream and depreciation schedule for any investment property may affect the property owner’s income bracket and/or tax status. An unfavorable tax ruling may cancel deferral of capital gains and result in immediate tax liabilities;
- Potential for foreclosure – All financed real estate investments have potential for foreclosure;
- Illiquidity – These assets are commonly offered through private placement offerings and are illiquid securities. There is no secondary market for these investments.
- Reduction or Elimination of Monthly Cash Flow Distributions – Like any investment in real estate, if a property unexpectedly loses tenants or sustains substantial damage, there is potential for suspension of cash flow distributions;
- Impact of fees/expenses – Costs associated with the transaction may impact investors’ returns and may outweigh the tax benefits
- Stated tax benefits – Any stated tax benefits are not guaranteed and are subject to changes in the tax code. Speak to your tax professional prior to investing.
Opportunity Zone Disclosures
- Investing in opportunity zones is speculative. Opportunity zones are newly formed entities with no operating history. There is no assurance of investment return, property appreciation, or profits. The ability to resell the fund’s underlying investment properties or businesses is not guaranteed. Investing in opportunity zone funds may involve a higher level of risk than investing in other established real estate offerings.
- Long-term investment. Opportunity zone funds have illiquid underlying investments that may not be easy to sell and the return of capital and realization of gains, if any, from an investment will generally occur only upon the partial or complete disposition or refinancing of such investments.
- Limited secondary market for redemption. Although secondary markets may provide a liquidity option in limited circumstances, the amount you will receive typically is discounted to current valuations.
- Difficult valuation assessment. The portfolio holdings in opportunity zone funds may be difficult to value because financial markets or exchanges do not usually quote or trade the holdings. As such, market prices for most of a fund’s holdings will not be readily available.
- Capital call default consequences. Meeting capital calls to provide managers with the pledged capital is a contractual obligation of each investor. Failure to meet this requirement in a timely manner could elicit significant adverse consequences, including, without limitation, the forfeiture of your interest in the fund.
- Opportunity zone funds may use leverage in connection with certain investments or participate in investments with highly leveraged capital structures. Leverage involves a high degree of financial risk and may increase the exposure of such investments to factors such as rising interest rates, downturns in the economy or deterioration in the condition of the assets underlying such investments.
- Unregistered investment. As with other unregistered investments, the regulatory protections of the Investment Company Act of 1940 are not available with unregistered securities.
- It is possible, due to tax, regulatory, or investment decisions, that a fund, or its investors, are unable realize any tax benefits. You should evaluate the merits of the underlying investment and not solely invest in an opportunity zone fund for any potential tax advantage.
The above material cannot be altered, revised, and/or modified without the express written consent of Urban Catalyst.
