OZ 2.0 Bill Heads To The Senate

The House has passed their OZ 2.0 bill as part of budget reconciliation. The bill now heads to the Senate. How should the Senate address OZ 2.0 and what are the next steps for doing so?

Plus, several key Opportunity Zone investing events are on the horizon.

About OZ NewsHour

OZ NewsHour covers the key stories happening right now in the world of Opportunity Zones. Hosts Andy Hagans and Jimmy Atkinson discuss the powerful trends that investors, fund managers, real estate developers, and industry professionals need to know. If it’s a must-know development in the Opportunity Zone world, we cover it here.

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Episode Summary

In this special OZ NewsHour edition, co-hosts Jimmy Atkinson and Andy Hagans break down the Opportunity Zones provisions in the House-passed budget reconciliation bill, preview next steps in the Senate, and share live updates on advocacy and upcoming OZ events.

What’s in the House-Passed OZ 2.0 Bill?

OZ provisions begin on page 886 of the 1,100-page House reconciliation bill.

Seven key OZ changes in this House version of the bill:

  1. New round of OZ designations from 2027–2033.
  2. Updated low-income community definition, which would result in 22% fewer zones.
  3. Early expiration of current OZ designations on 12/31/2026 (instead of 12/31/2028).
  4. Increased focus on rural designations and incentives.
  5. Elimination of the 15% basis step-up; retention of only the 10-year hold benefit (now after 5 years).
  6. $10,000 cap on ordinary income eligible for OZ benefits.
  7. No interim gain relief, no fund-of-funds support, and no permanence.

Jimmy’s Editorial: Missed Opportunities & Capital Freeze Risk

Jimmy highlights key concerns:

  • No permanent extension, despite the program’s bipartisan success.
  • $10k ordinary income cap is functionally irrelevant given fund minimums.
  • Eliminating the 15% step-up weakens investor incentives.
  • No safe harbor for developers or clarity on existing tracts post-2026.
  • The biggest risk: A looming capital freeze from 2025–2026 due to investor uncertainty.

Senate Outlook & Advocacy Campaign

  • Senate likely to rewrite OZ language “from scratch,” led by Sen. Tim Scott and Sen. Mike Crapo.
  • OpportunityZones.com has launched an updated sign-on letter with five key asks:
    1. Make OZs permanent.
    2. Provide interim gain relief.
    3. Prevent capital freeze during transition.
    4. Enable fund-of-funds.
    5. Expand ordinary income participation beyond $10k.
  • Stakeholders can view and sign the letter at: opportunityzones.com/advocacy

OZ Events Recap & Preview

  • Washington DC Summit: Hosted by Sen. Tim Scott’s Great Opportunity Policy Inc.; attended by Sen. Mike Crapo, Ben Carson, HUD Secretary Scott Turner, and others. Key takeaway: Senate leadership strongly supports OZ permanency.
  • Upcoming OZ Pitch Day: Multiple OZ deals and funds presenting, including Capital Square, Altes Capital, YourSpace America, Urban Catalyst, Sinatra & Co., and Centennial Advisers. Expert panels will discuss Trump tax cuts, including OZs and bonus depreciation.
  • OZ Insiders Dinner: June 3 in Manhattan Beach, CA — Limited seats remain.
  • Capital Square Event: June 4 in Richmond, VA. OZ legislation panel + walking tour of local projects.
  • OZ Insiders Masterclass (June 9): Featuring DJ Van Keuren on family office real estate investing.

Fun Fact: Pope Leo XIV Grew Up in an OZ

Jimmy reveals that the newly elected Pope Leo XIV’s childhood home and parish (St. Mary of the Assumption) are both located in Chicago Opportunity Zones—highlighting a unique convergence of faith and tax policy.

Picks of the Month

  • Jimmy: His recent article on Pope Leo XIV’s South Side Chicago OZ roots.
  • Andy: OZ Pitch Day — likely the biggest ever, with critical updates on tax reform and OZ 2.0.