Novogradac’s 2025 OZ Summit: What’s Next for OZ 2.0
The Opportunity Zone industry’s top professionals will gather in Las Vegas on December 3, 2025, for the Novogradac 2025 Opportunity Zones Summit, a one-day event at the Four Seasons dedicated to unpacking the next chapter of Opportunity Zones 2.0.
Novogradac partners Jason Watkins and Kevin Wilson join the show to preview the summit, share the latest fundraising and compliance trends, and discuss what Treasury guidance may look like as the industry transitions from OZ 1.0 to OZ 2.0.
Guests: Jason Watkins & Kevin Wilson
- Jason Watkins on LinkedIn
- Kevin Wilson on LinkedIn
- Novogradac & Company
- Novogradac 2025 Opportunity Zone Summit (Use promo code OZ10)
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 episode of The Opportunity Zones Podcast, Jimmy Atkinson welcomes Jason Watkins and Kevin Wilson, both partners at Novogradac & Company, to preview the upcoming Novogradac 2025 Opportunity Zones Summit in Las Vegas and discuss the latest developments surrounding Opportunity Zones 2.0. The conversation covers OZ fundraising trends, regulatory priorities, rural incentives, and expectations for Treasury guidance as the industry transitions from OZ 1.0 to OZ 2.0.
About Novogradac & Company
Jason introduces Novogradac as a national, full-service accounting firm specializing in tax credit transactions, including Opportunity Zones, low-income housing, new markets, renewable energy, and historic tax credits. He notes that the firm was involved in OZ policy discussions even before the incentive was introduced in Congress. Kevin adds that Novogradac assists investors at every stage—from transaction structuring and financial modeling to compliance and tax filings—helping clients navigate evolving OZ regulations.
Opportunity Zone Fundraising Trends
Jimmy highlights Novogradac’s quarterly fundraising survey, which tracks equity raised by Qualified Opportunity Funds (QOFs). Jason reports that through Q2 2025, funds raised over $1 billion in new equity, one of the strongest quarters in recent years. He notes that while many expected a “dead zone” in capital formation leading up to 2026, fundraising has remained steady.
Kevin points out that those results preceded the passage of OZ 2.0 in July 2025, suggesting that upcoming surveys could show a further uptick as the new law creates long-term stability. Jason expects fundraising to flatten slightly in 2026 before surging again in 2027, when the new five-year deferral and 10 percent basis step-up become available for gains invested on or after January 1, 2027.
OZ 2.0: Transition and Implementation Challenges
Turning to OZ 2.0, Jimmy asks what Novogradac is hearing from clients and what issues they’re tracking. Kevin says renewed excitement is palpable, with practitioners and community developers eager to deploy capital under the new permanent framework. Still, several open questions remain around implementation.
Jason explains that Novogradac’s Opportunity Zones Working Group has been preparing a series of comment letters to Treasury, focusing first on transition guidance from OZ 1.0 to 2.0. A top priority is clarifying what happens when existing OZ tracts lose designation on December 31, 2028, and ensuring that projects already underway can continue to qualify for OZ benefits. He emphasizes the need for Treasury to provide explicit rules so developers and investors maintain confidence in ongoing projects.
Kevin adds that a prior bill, the Opportunity Zone Transparency, Extension, and Improvement Act (OZTIEA), contained language that could address this issue. Although never enacted, they hope Treasury will incorporate similar provisions in forthcoming regulations.
Overlap Between OZ 1.0 and OZ 2.0 Tracts
Jimmy asks about the two-year overlap between OZ 1.0 and OZ 2.0 zones in 2027–2028. Jason confirms that OZ 2.0 dollars invested during that period should be deployable into existing OZ 1.0 tracts through the end of 2028. Kevin agrees, noting that this overlap is one of the most common questions they receive.
Rural Incentives and Substantial Improvement Thresholds
The discussion turns to IRS Notice 2025-50, which lists rural OZ tracts eligible for a reduced 50 percent substantial improvement threshold, down from the usual 100 percent. Jason calls the change a major incentive for rural investment and praises Treasury for issuing guidance quickly. However, he says Novogradac is seeking clarification on whether the rule applies retroactively to properties acquired or improved before July 4, 2025.
Kevin notes that this rural incentive differs from another provision—a larger basis step-up for investments in rural Qualified Opportunity Funds—which takes effect in 2027. The firm’s working group will request confirmation on both points in its initial Treasury letter.
Puerto Rico Designation Clarification
Jason also highlights uncertainty around the special rule for Puerto Rico, which is scheduled to expire December 31, 2026. Novogradac is asking Treasury to confirm whether that expiration applies only to future designations or also to existing OZ tracts on the island. The firm believes the intent is for Puerto Rico’s current tracts to remain active through 2028, consistent with the rest of the U.S., but wants an explicit ruling.
Aligning OZs With Affordable Housing
Kevin mentions ongoing conversations about better aligning OZs with the Low-Income Housing Tax Credit (LIHTC) program. Currently, Opportunity Zone projects require a 100 percent substantial improvement, while LIHTC deals have a lower threshold. Novogradac believes Treasury could use regulatory authority to harmonize these requirements, facilitating joint OZ–LIHTC developments.
Preview: Novogradac 2025 Opportunity Zones Summit
The episode then shifts to previewing the upcoming Novogradac 2025 OZ Summit, taking place December 3, 2025, at the Four Seasons Las Vegas. Jason and Kevin outline what attendees can expect:
- Washington Report opening panel covering the latest legislative and regulatory updates
- Detailed OZ 2.0 panel reviewing key statutory changes and new incentives
- Operating Business and Rural Focus panels featuring companies leveraging OZ capital for growth
- Networking opportunities throughout the day, connecting investors, fund managers, and advisors
- Regulatory guidance panel exploring what Treasury can clarify through rulemaking versus what requires new legislation
Jason notes that this year’s event will likely be the largest OZ Summit in years, with registration already matching or exceeding last year’s Washington D.C. turnout. Kevin adds that the permanence of the incentive has reignited institutional interest, reversing the decline in attendance seen as the original 2026 sunset approached.
Jimmy reflects on past conferences—from Long Beach and Cleveland to D.C.—and recalls the excitement surrounding the 2024 election results that paved the way for OZ 2.0. He predicts record attendance this year as more family offices, RIAs, accounting firms, and law firms re-engage with Opportunity Zones now that the program is permanent.
Novogradac’s Ongoing Policy Work
Kevin emphasizes that the firm’s policy advocacy is not finished. Beyond transition rules, Novogradac continues to push for additional enhancements through future legislation or bipartisan tax packages. Jason invites listeners to explore the firm’s Opportunity Zones Working Group webpage—accessible via Novoco.com or a simple Google search—to view all published comment letters and ongoing initiatives.
Registration and OZ Insiders Dinner
Jimmy reminds listeners that they can save 10 percent on registration for the Novogradac 2025 OZ Summit using promo code OZ10 at checkout on Novoco.com. He also announces the OZ Insiders Members Dinner, to be held the evening before the summit (December 2) at Mandalay Bay. Members can RSVP at OZInsiders.com.
Closing
The conversation concludes with mutual excitement for the December events and optimism about the future of the Opportunity Zone program under its new permanent framework. Jimmy thanks Jason and Kevin for their insights and encourages listeners to visit OpportunityZones.com/podcast for show notes, registration links, and resources mentioned in the episode.