What happens when OZ 1.0 and OZ 2.0 collide? On this edition of OZ NewsHour, Andy Hagans and Jimmy Atkinson explain the unique 2027–2028 overlap, how long the original tracts remain active, and why the next phase of Opportunity Zones may be the most exciting yet.
Plus, a preview of several upcoming industry events.
Opportunity Zone News & Events
- Opportunity Zones 2.0 Explained (OpportunityZones.com)
- EIG Map of OZ 2.0 Eligible Tracts (EIG/ArcGIS)
- More than $1 Billion in Equity Raised in Q2 (Novogradac)
- Novogradac 2025 OZ Summit (Use discount code OZ10)
- OZ Insiders Calendar of Upcoming Events
- GOP Reshapes Opportunity Zones to Target Trump Country (WSJ)
- OZ Pitch Day Fall 2025 (Nov 13, 2025)
- Qualified Opportunity Zones 2.0: permanence, incentives, and more (DJC)
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 August 2025 edition of OZ NewsHour, co-hosts Andy Hagans and Jimmy Atkinson dive into the most pressing questions surrounding Opportunity Zones in light of the newly enacted Opportunity Zones 2.0 legislation. With the “One Big Beautiful Bill” making the program permanent and introducing sweeping changes, the episode explores what investors and fund managers can expect as the new census tracts take effect in 2027, while the original tracts from 2018 continue to sunset.
Which Opportunity Zones Will Be Available in 2027?
Jimmy explains that from January 1, 2027, through December 31, 2028, there will be a two-year overlap period when both OZ 1.0 and OZ 2.0 census tracts are available for investment. OZ 1.0 tracts, designated in 2018, remain eligible until their 10-year statutory expiration on December 31, 2028. Meanwhile, OZ 2.0 tracts become effective starting January 1, 2027. This overlap allows Qualified Opportunity Funds (QOFs) to deploy capital into either set of zones during that period.
Jimmy highlights that many OZ 1.0 tracts may appear more attractive to investors due to their looser eligibility rules in 2018, the inclusion of certain contiguous tracts, and the fact that many have seen substantial growth since designation. However, Andy notes that much of the “low-hanging fruit” may already have been developed, while OZ 2.0 will bring entirely new opportunities in areas that have not previously qualified.
OZ 2.0 Tax Benefits vs. OZ 1.0
Starting in 2027, investors rolling gains into QOFs will benefit from new OZ 2.0 incentives:
- A five-year rolling deferral period.
- A 10% basis step-up at the five-year mark (30% for rural OZ investments).
- Continued 10-year exclusion of capital gains on appreciation.
- The ability, during 2027–2028, to place OZ 2.0 capital into OZ 1.0 projects and still receive OZ 2.0 benefits—though IRS guidance may further clarify the rules.
Jimmy emphasizes that this overlap is unique and will not repeat in future decades, when expiring tracts and new tracts will align seamlessly.
Fundraising Momentum in 2025
Turning to fundraising, Jimmy and Andy review Novogradac's latest report showing more than $1 billion raised by QOFs in Q2 2025. To date, Novogradac has tracked $42 billion raised across more than 2,000 funds, though they estimate this represents only a quarter to a third of the total market. Using a multiplier, Jimmy estimates total OZ fundraising has surpassed $160 billion since inception.
They attribute this resurgence partly to bullish investor psychology, with stocks, real estate, and crypto all near highs. Investors sitting on recent capital gains may be more inclined to deploy into QOFs now, even before OZ 2.0 takes effect.
Upcoming Events
Jimmy announces several key industry events:
- OZ Insiders DFW Dinner – September 4, 2025, at the Hotel Drover in Fort Worth, TX (an Opportunity Zone).
- OZ Pitch Day Fall 2025 – November 13, 2025 online. Free registration is now open.
- Novogradac 2025 Opportunity Zone Summit – December 3, 2025, at the Four Seasons Las Vegas, with Jimmy attending, speaking, and recording live podcast episodes. Registration discounts are available with code OZ10.
- OZ Insiders Vegas Dinner – December 2, 2025, in Las Vegas, coinciding with the Novogradac Summit.
- Monthly OZ Insiders Masterclasses – Covering CRE market updates, OZ 2.0 rural incentives, reporting compliance requirements, and lobbying strategies for designation in 2026.
Recordings of all past masterclasses and meetings are available to OZ Insiders members, including recent sessions on minimizing 2026 tax bills and real-time analysis of the OZ 2.0 legislative text.
Rural Incentives in OZ 2.0
The hosts highlight a Wall Street Journal article framing OZ 2.0 as an opportunity to channel capital into “Trump country,” given the stronger emphasis on rural development:
- Substantial Improvement Test: In rural areas, the requirement is reduced from 100% to 50% of adjusted basis.
- Basis Step-Up: Rural OZ investors receive a 30% basis step-up after five years, compared to 10% for non-rural zones.
Jimmy notes early interest from investors in industrial projects, infrastructure, energy, broadband, and even ag-tech opportunities in rural tracts—sectors that could benefit from the new incentives.
Pick of the Month
- Jimmy’s Pick: Registration is now open for OZ Pitch Day on November 13, 2025. The virtual event will feature presentations from developers and fund managers, expert panels, and Jimmy’s keynote on the OZ 1.0 vs. OZ 2.0 overlap.
- Andy’s Pick: An article by Coni Rathbone in Law.com titled “One Big Beautiful Bill Act Creates Opportunity Zones Incentives Including New Bonus Depreciation Rules.” Andy recommends it as an accessible breakdown of the major OZ 2.0 changes, especially the powerful bonus depreciation provisions.
Conclusion
The hosts conclude by reiterating the unique opportunity presented by the 2027–2028 overlap, the strong fundraising momentum heading into OZ 2.0, and the growing excitement among investors and sponsors. They encourage listeners to attend upcoming events, join OZ Insiders for insider access to analysis and education, and stay tuned for further updates as OZ 2.0 implementation unfolds.