What We Learned At The OZ 2.0 Summit, With Jim Lang

Last week, as the House passed a critical budget resolution that opened the door for major tax legislation, Opportunity Zone industry leaders converged in Park City, Utah to chart the policy’s future.

Recorded on-site at the Yellow Brick Road to QOZ 2.0 event, Jim Lang of Greenberg Traurig joined the show to share key takeaways from the conference—including what’s likely to make it into forthcoming Opportunity Zones 2.0 legislation.

Guest: Jim Lang, Greenberg Traurig

About The Opportunity Zones Podcast

Hosted by OpportunityZones.com founder Jimmy Atkinson, The Opportunity Zones Podcast features guest interviews from fund managers, advisors, policymakers, tax professionals, and other foremost experts in the Opportunity Zones industry.

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Episode Summary

In this on-site episode of The Opportunity Zones Podcast, host Jimmy Atkinson sits down with Jim Lang of Greenberg Traurig at the 2025 “Yellow Brick Road to QOZ 2.0” conference, hosted at the Montage Deer Valley in Park City, Utah. Against a backdrop of spring sunshine and fresh snow, Jimmy and Jim reflect on the policy momentum, legislative developments, and cross-sector energy that define this pivotal industry event.

A Diverse Cross-Section of the OZ Ecosystem

Jim highlights the impressive diversity of attendees, noting that this wasn’t just a room full of real estate developers. The conference brought together stakeholders from across the Opportunity Zone space, including:

  • Representatives from major Qualified Opportunity Funds (QOFs).
  • Operators in renewable energy and onshore manufacturing.
  • Sponsors of affordable housing and rural development projects.
  • Startups and critical minerals processing ventures.
  • Economic development groups and OZ policy experts.

Panels ranged from project showcases to discussions about complex capital stacks, regulatory improvements, and how to expand OZ participation beyond real estate. All four projects highlighted on the project panel were high-impact and aligned with the spirit of the incentive.

Breaking News: Budget Resolution Passed Mid-Panel

In a timely coincidence, the U.S. House of Representatives passed the Senate’s budget resolution while Jimmy and Jim were on stage for a policy panel. This development unlocks the budget reconciliation process—allowing for the advancement of Trump’s 2025 tax agenda, including a potential Opportunity Zones 2.0 package.

Jim emphasizes how fortunate the timing of this conference was. With reconciliation now underway, policy discussions and community feedback from this event can directly influence the next version of OZ legislation.

Challenges and Lessons from the First 7 Years

While Opportunity Zones have seen significant success—attracting billions of dollars and revitalizing communities—Jim believes it’s the challenges that provide the best roadmap for reform. A few key takeaways:

  • Real estate still dominates OZ investing, likely representing 75–90% of total OZ equity.
  • There is a need to expand OZ usage in operating businesses, particularly those in healthcare, logistics, clean energy, and critical minerals.
  • Rural projects remain underrepresented and require targeted support.
  • The program has untapped potential to become a leading tool for affordable and workforce housing.

Jim sees the current moment as an opportunity to fine-tune the policy to make it more inclusive, dynamic, and impactful across a wider range of industries.

Policy Priorities for OZ 2.0

Jimmy and Jim outline several key enhancements that the industry hopes to see in the next round of legislation. Among the most discussed ideas:

  • 10-Year Extension: While full permanence may be difficult under reconciliation rules, a 10-year pushout is seen as essential for creating long-term confidence and viability.
  • Rolling Deferral Windows: Investors would have the ability to roll capital gains into OZs within a fixed window after realization, removing the hard deadline structure that currently limits participation.
  • Step-Up Basis Restoration: Bringing back the 10% or 15% step-up basis for long-term OZ investors, which expired at the end of 2021.
  • Interim Gain Rollover: Allowing investors to sell within the 10-year window and reinvest into new projects without triggering inclusion, enabling capital recycling and increased economic impact.
  • Ordinary Income Eligibility: Currently, only capital gains qualify for OZ investments. Expanding eligibility to include ordinary income would democratize the incentive and allow participation from banks and tax-exempt entities that don’t generate capital gains.

Bringing Banks into the OZ Ecosystem

One major theme from the conference was the need for debt capital and the role banks can play in scaling OZ activity. Jim explains that banks have largely been absent from the OZ market due to their lack of capital gains and unclear CRA (Community Reinvestment Act) treatment.

Potential reforms include:

  • Allowing OZ investments to count toward CRA credit.
  • Expanding the tax benefit to debt instruments in targeted industries (housing, manufacturing, disaster relief).
  • Providing tax exemptions for banks that invest in OZs.

Jim believes these reforms could catalyze significant institutional capital inflows and open new deal pathways.

A Surge in Support for Onshoring & Strategic Industries

The conference also featured discussion around OZs supporting national industrial policy. Attendees shared examples of:

  • Critical minerals processing
  • Shipbuilding and maritime industries (in light of a new maritime-focused executive order)
  • Healthcare innovations in rural Appalachia
  • Sports-related development and team ownership in OZs
  • Renewable energy and green infrastructure

Jimmy mentions a nuclear submarine builder in Mobile, Alabama, operating within an OZ. Jim notes that these kinds of unexpected success stories are proof that the incentive has broad applications beyond multifamily construction.

Next Steps for Advocacy

As momentum builds toward legislation later this year, Jim closes with a call to action for stakeholders:

  1. Engage with Members of Congress: Reach out to your representatives and senators. If possible, invite them to tour impactful OZ projects in their districts.
  2. Contact the Administration: Direct outreach to White House staff and agency officials can help shape the policy narrative.
  3. Tell Your Story: Highlight community impact, business creation, job growth, and innovation—especially for projects outside traditional real estate.
  4. Write Letters: Jim mentions that model letters may soon be available for advocates to send to lawmakers and policy staff.
  5. Collaborate with Policy-Oriented Groups: Organizations like the America First Policy Institute, Economic Innovation Group (EIG), Novogradac’s OZ Working Group, and the OpportunityZones.com community are playing a pivotal role in shaping the next phase of OZ policy.

Conclusion

The Yellow Brick Road to QOZ 2.0 conference may have been small in size, but it was big on influence. With reconciliation unlocked and OZ legislation potentially on the table later this year, the conversations, coalitions, and ideas coming out of Park City will be instrumental in charting the course for the program’s future. Jim Lang and Jimmy Atkinson both agree: the opportunity to enhance Opportunity Zones has never been greater.