Governors Are Picking New Opportunity Zones Right Now

The OZ 2.0 map is being drawn right now. Five jurisdictions have already sent tract nominations to Treasury, and the other 51 have until September 28 to decide.

On this episode of OZ Live, Jimmy Atkinson and Andy Hagans walk through where all 56 states and territories stand in the OZ 2.0 nomination process, and the key dates and deadlines between now and the January 1, 2027 effective date. Plus, Treasury's new $112 billion Opportunity Zone report, IRS Notice 2026-40's rules for bridging OZ 1.0 projects into OZ 2.0, and a first look at the redesigned OpportunityZones.com and its new OZ Investment Marketplace.

Mentioned on This Episode

• OZ 2.0 State Tracker (OppotunityZones.com)
• Inside Treasury's $112 Billion Opportunity Zone Report (OpportunityZones.com)
• Use of the Opportunity Zone Tax Incentive through 2024: An Update (U.S. Treasury)
• New Treasury Data Emphasize Why OZ Designations Matter (EIG)
• OZ 2.0 Superwebinar, covering IRS Notice 2026-40 (OpportunityZones.com)
• How to Bridge OZ 1.0 Projects to OZ 2.0 (OZ Insiders Masterclass)
• OZ Insiders Dinner in Fort Worth TX (September 9, 2026)
• OZ Insiders Dinner in Washington DC (October 28, 2026)
• Opportunity Zone Investment Marketplace (OpportunityZones.com)
• Get listed on the OZ Marketplace (OpportunityZones.com)
• Long-Delayed Tax Bill Comes Due for Opportunity Zone Investors (WSJ)
• Leyla Kuni on X

About OZ Live

OZ Live is the monthly livestream hosted by Andy Hagans and Jimmy Atkinson of OpportunityZones.com, as part of The Opportunity Zones Podcast.

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Episode Summary

Andy Hagans welcomed listeners back to the show, now rebranded as OZ Live, alongside Jimmy Atkinson. The show took the summer off and returns focused on the OZ 2.0 era as the industry gears up for 2027.

OZ 2.0 State Tracker: Where Nominations Stand

Jimmy explained that a new Opportunity Zones map takes effect January 1, 2027, running alongside the current map as the old program winds down. Each state's governor's office nominates OZ 2.0-eligible tracts to the U.S. Department of Treasury for official designation, a process mirroring what played out in spring 2018. Jimmy built the OZ 2.0 State Tracker with help from Frances Kern Mennone at FBT Gibbons, who feeds him regular updates on state-by-state activity.

On the tracker, yellow marks a state whose nomination window has closed and whose list is sitting with the governor's office awaiting submission to Treasury; blue marks a state that has submitted its nominations to Treasury; green marks a state still taking local input through an open process; and gray marks a state that hasn't started a formal process publicly.

Jimmy said most states are on track, but flagged New York, Connecticut, and Nevada as states he hasn't seen anything from yet, and said he'd like more public progress from Montana, North Dakota, and South Dakota.

Arizona Leads, New York Lags

Jimmy named Arizona the clear standout, having submitted 125 tract nominations to Treasury on July 9, three of them off-list tract nominations — tracts not on Treasury's official eligible list, submitted with supporting data to argue for inclusion. The 122 on-list tracts are expected to receive straightforward approval, while the three off-list tracts require Treasury adjudication.

Nebraska and the Virgin Islands also earned praise for submitting and publishing their tract lists; Alaska and Kansas have submitted but not yet published theirs; and Colorado has submitted two off-list tracts without yet finalizing its full list.

Jimmy singled out New York, which needs to nominate approximately 426 OZ 2.0-eligible tracts but hasn't published any public guidance. The nomination deadline is September 28, with states able to request a 30-day extension from Treasury that would push it to October 28.

Treasury's $112 Billion Report

Jimmy turned to the Treasury working paper published in mid-July, "Use of the Opportunity Zone Tax Incentive through 2024: An Update," a 37-page report by David Coyne and Craig Johnson of Treasury's Office of Tax Analysis. The headline number: $112 billion of Opportunity Zone investment through year-end 2024.

Citing an Economic Innovation Group overview, Jimmy pointed to roughly 12,800 active Qualified Opportunity Funds nationwide, investment capital from 41,000 different taxpayers, $116 billion in assets, and a 77 percent reach figure: of the more than 7,800 census tracts across the 50 states and D.C., over 6,000 received at least some OZ investment.

Andy pointed to a chart in the EIG write-up plotting QOF assets and deferred gains from 2018 through 2024, noting the deferred-gains line's slope shifts sharply downward around 2021 and 2022 as the original step-up benefits expired, since OZ 1.0 wasn't a rolling deferral the way OZ 2.0 is under OBBBA. He predicted OZ 2.0's rolling deferral will produce steadier, more consistent capital raising rather than the front-loaded pattern seen under OZ 1.0, and Jimmy agreed, predicting a long-term trend slope "slightly greater than one."

Both credited the Treasury figure with vindicating years of estimates from Novogradac's quarterly survey, which had only been capturing perhaps a quarter to a third of the total OZ investment universe.

IRS Notice 2026-40 and the OZ Insiders Masterclass

Jimmy explained that IRS Notice 2026-40 addresses whether capital can still be raised and deployed into OZ 1.0 projects after 2026, potentially into 2028 — the answer is yes, conditionally.

OZ Insiders covered the notice in a Masterclass with Jim Lang of Greenberg Traurig, "How to Bridge OZ 1.0 Projects to OZ 2.0," which Jimmy and Andy called the best-attended Masterclass the group has ever run, drawing over 40 attendees against a typical 25 to 30, as OZ Insiders membership has grown past 100. The recording is available on demand to OZ Insiders members.

Members also have two upcoming networking dinners: one in Fort Worth at Del Frisco's Grille (September 9), and a larger one, seating up to 100, the night before the Novogradac Opportunity Zones conference at Chef Geoff's West End in Georgetown, Washington DC (October 28).

A Redesigned Website, New Map, and the OZ Investment Marketplace

Andy highlighted a full redesign of every page on OpportunityZones.com, including a rebuilt interactive map with toggleable layers that will be updated with new OZ 2.0-eligible tracts throughout the fall and into next year.

The site's new central feature is the OZ Investment Marketplace, where investors can browse open Opportunity Zone deals using filters for sector, location, region, and minimum investment. Each listing includes images, a downloadable investor deck, the sponsor's OZ Pitch Day presentation where applicable, and a contact form routed directly to the sponsor.

Jimmy noted that OpportunityZones.com is not a broker-dealer, does not act as a financial advisor, and hasn't conducted due diligence on any listed deal, so that burden remains with the investor, but confirmed every listed deal is real, open, and from a vetted sponsor he's spoken with directly. Nineteen deals are currently listed, including the Kinect Real Estate Partners Gresham OZ Fund, investing in ground-up multifamily development just outside Portland, Oregon.

Sponsors can list at opportunityzones.com/sponsorship; a standard listing runs for a six-month term starting at $5,000 and is included automatically for OZ Pitch Day sponsors.

Pick of the Month

Jimmy's pick of the month was a Wall Street Journal article, "Long-Delayed Tax Bill Comes Due for Opportunity Zone Investors" by Richard Rubin, which notes Treasury is likely to receive tens of billions of dollars in deferred capital gains payments and estimates a $29 billion one-time tax revenue bump.

The article quotes Jason Watkins, chairman of the Novogradac Opportunity Zones working group and an OZ Insiders member, on the sizable tax bill coming due for OZ investors, and includes a quote from Jimmy on smart investors keeping their eye on the ten-year benefit.

Andy's pick was Leila Kunimoto, whose newsletter, Convestor Insights, at accreditedinsight.com, covers alternative investments and private funds from the LP point of view, alongside a sharp, funny presence on X holding sponsors accountable.