The new Senate bill proposes some major changes to Opportunity Zones, including:
• OZ permanence, with decennial OZ cycles. New zones every 10 years, each with a fixed 10-year life and gain recognition date.
• Revised basis step-up schedule. An annual basis step-up accrual model replaces the old 5- and 7-year cliffs.
• Rural OZ boost. A 3× basis multiplier and relaxed improvement test for rural-focused QOFs.
• Tighter eligibility rules for zone designation. New low-income community definition (= 70% MFI) and elimination of the “contiguous tract” rule could sharply reduce qualifying areas.
• Puerto Rico carve-out removed. The island loses its blanket OZ designation and becomes subject to the 25% tract cap.
On the panel, GT Shareholder Jim Lang and Blake Christian from HCVT will cover each of these changes, plus what's not in the bill that we think should be.
They will also discuss other landmark provisions in the new tax bill, including 100% Bonus Depreciation, Section 199A QBI Deduction, and SALT Cap Relief.