The Qualified Opportunity Zone program is entering a new era. In this episode of Greenberg Traurig's Big Law Redefined Podcast, guest host Hayden Dempsey, chair of the firm’s Florida Government Law & Policy Practice, sits down with Shareholder Jim Lang, who leads GT's Qualified Opportunity Zone national team, to break down the sweeping changes brought by the One Big Beautiful Bill and what they mean for developers, investors, and fund sponsors across the country.
Jim and Hayden walk through the most consequential shifts from QOZ 1.0 to QOZ 2.0, starting with the program's new permanent status, which replaces what had been a framework set to expire on Dec. 31, 2026.
They discuss the rolling five-year tax deferral replacing the hard-coded deferral deadline, the redesignation process launching July 1, 2026, and why this round of zone selections will be more targeted and deliberate than the rushed 2018 designations.
The conversation also covers the newly created Qualified Rural Opportunity Fund category and its significantly enhanced tax incentives, including a 30% basis step-up after a five-year hold compared to the standard 10%, as well as a reduced substantial improvement threshold for rural properties.
Jim and Hayden also address how governors are approaching the designation process, why advocacy at the state and local level matters more than ever, and how local governments can align their land use and permitting frameworks to attract private capital into designated zones.
Finally, they talk about the new reporting and compliance requirements coming under 2.0 and the critical transition period between now and Dec. 31, 2028, when the old and new zone maps will overlap and key questions about cross-investment between 1.0 and 2.0 tracks remain pending further guidance.
Tune in!