A term has been making the rounds among Opportunity Zone practitioners: the "dead zone." It refers to 2026 — a year in which new investments into Qualified Opportunity Funds carry meaningfully weaker tax benefits than investments made either several years ago or starting January 1, 2027. The name is attention-grabbing. The mechanics behind it are real. But for fund managers paying attention, the dead zone is less a threat than a transition — and one that rewards preparation. What the Dead...

The 90% asset test is the structural backbone of QOF compliance. Failing it triggers financial penalties. Failing it repeatedly creates legal and investor-relations exposure that compound over time. Under OZ 2.0, the stakes are higher — and the data required to document compliance is more detailed than ever. What the 90% Asset Test Requires Every Qualified Opportunity Fund is legally required to hold at least 90% of its total assets in qualified opportunity zone property (QOZP) — meaning...

The Opportunity Zone program is now permanent law. But the rules that govern a fund depend entirely on when its investors committed capital — and the differences are significant. Fund managers operating across both regimes face a dual compliance reality that will persist for years. A Program Made Permanent When Congress created the Opportunity Zone program in 2017, it built in a sunset. The program was temporary by design, with investment eligible only through December 31, 2026, and deferred...