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Top 10 Counties For Opportunity Zones 2.0

JAJimmy Atkinson·September 2, 2025 · 4 min read
Top 10 Counties For Opportunity Zones 2.0

On this month’s live episode of OZ Office Hours, OpportunityZones.com founder Jimmy Atkinson discusses the top 10 counties for Opportunity Zone 2.0 designations, plus answers live questions from the audience.

Join Jimmy the first Monday of every month at 3:00 PM Eastern Time, to get your Opportunity Zones questions answered live.

Featured On This Episode

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 live September 2025 edition of Opportunity Zone Office Hours, Jimmy Atkinson explores the Top 10 Counties for Opportunity Zones 2.0 and answers audience questions on the evolving OZ landscape.

This episode provides a deep dive into where the next wave of OZ investment opportunities will be located, how state-level decision making may unfold, and why OZ 2.0’s permanence could supercharge both investor participation and community impact.

Jimmy begins by highlighting that Los Angeles County, Cook County (Chicago), and Harris County (Houston) lead the nation with the highest number of OZ 2.0–eligible tracts, with seven more counties rounding out the top 10: Kings County (Brooklyn), Wayne County (Detroit), Dallas County (Dallas), Bronx County (NYC), Miami-Dade County (Miami), Maricopa County (Phoenix), and Philadelphia County (Philadelphia).

He notes that while these counties have the most eligible tracts, actual designations may be reduced due to governors prioritizing rural areas under new OZ 2.0 incentives.

Counties With The Most OZ 2.0 Eligible Tracts

CountyOZ 2.0 Eligible Tracts% of State Total
Los Angeles County, CA84534%
Cook County, IL49249%
Harris County, TX48320%
Kings County, NY39324%
Wayne County, MI33439%
Dallas County, TX28812%
Bronx County, NY26916%
Miami-Dade County, FL24518%
Maricopa County, AZ23947%
Philadelphia County, PA23326%

Jimmy thanks Novogradac and its Opportunity Zones Working Group, led by Jason Watkins, for releasing a new map tool on PolicyMap.com that visualizes likely OZ 2.0–eligible tracts. He explains the color coding for eligibility and rural status, stressing that while the map is not final, it is directionally accurate and expected to be 95%+ correct once the Treasury certifies eligible tracts in 2026. Governors will then have until late 2026 to submit their nominations, with new designations taking effect January 1, 2027.

He also outlines his own detailed spreadsheet analysis projecting state-by-state OZ 2.0 eligibility. Overall, Jimmy expects about 6,530 Opportunity Zones nationwide—a 25% reduction compared to OZ 1.0—due to tightened eligibility standards.

Jimmy then takes viewers through the map in detail:

  • Los Angeles County: By far the largest county by area and population, with widespread OZ eligibility across South and East LA, Downtown, and Long Beach. Rural status unlikely.
  • Cook County (Chicago): Heavy OZ eligibility on the South and West Sides, with limited designations expected on the North Side or Loop.
  • Harris County (Houston): Over 1,100 eligible tracts spread across the metro, with some uncertainty on rural status in surrounding areas.
  • New York City: Kings County (Brooklyn) and Bronx County both have extensive eligibility; Manhattan has very few eligible areas.
  • Dallas County: Limited zones compared to state totals, with concentrations on the South Side. Jimmy highlights Fort Worth’s Stockyards area—site of his upcoming OZ Insiders dinner at Hotel Drover—as an active OZ location (in the adjacent Tarrant County).

OZ Insiders Upcoming Events

Alongside the county-by-county breakdown, Jimmy shares updates on OZ Insiders, his mastermind group for high-performing OZ professionals. Upcoming events include:

  • September 4: Private dinner at Hotel Drover in Fort Worth, TX.
  • Monthly Zoom masterclasses: Topics include CRE market updates (Todd Vitzthum), OZ 2.0 rural incentives, reporting compliance for 2026, and lobbying for OZ 2.0 designations (led by EIG’s Kennan Fikri and Catherine Lyons).
  • December: In-person dinner in Las Vegas, coinciding with the Novogradac OZ Summit.

He recaps last month’s popular masterclass with Blake Christian, which focused on minimizing 2026 OZ tax bills, including strategies around fair market value discounts for nonmarketable, noncontrolling fund interests.

Live Q&A

During Q&A, Jimmy addresses a range of questions:

  • Partisan support: While branded a “Trump program,” OZs originated with bipartisan backing from Cory Booker and Tim Scott. At the state and local level, support remains strong across both blue and red jurisdictions.
  • State readiness: Unlike OZ 1.0’s rushed 90-day process, OZ 2.0 allows over a year of preparation before nominations begin in July 2026, giving states and governors more time to make thoughtful designations.
  • Capital availability: With unrealized gains estimated near $10 trillion, Jimmy foresees significant inflows into OZ funds in the OZ 2.0 era—potentially reaching $1 trillion of invested capital in coming years.
  • Industrial investment: OZ 2.0 rural incentives could spur more manufacturing and job-creating industrial projects, not just warehouses.
  • Individual investors: Options include creating a self-directed QOF to directly own property in an OZ, or investing passively into professionally managed QOFs listed on OpportunityZones.com/funds.
  • Census tract adjacency: While OZ 1.0 allowed limited use of adjacent tracts, OZ 2.0 will not broadly extend eligibility across streets or boundaries. However, governors may avoid illogical splits during designation.

Conclusion

Jimmy closes by encouraging listeners to explore the Novogradac map, browse the curated list of QOFs and deals on OpportunityZones.com, and consider joining OZ Insiders for access to advanced education, networking, and events.

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