Trump Signs Megabill: Opportunity Zones Made Permanent

President Trump’s signature on H.R. 1, the One Big Beautiful Bill, enacted OZ 2.0 and made Opportunity Zones a permanent feature of the tax code.

In this live episode, Jimmy Atkinson and Andy Hagans recap Congressional passage of H.R. 1 and the signing ceremony at the White House. Plus, a breakdown of exactly how OZ 2.0 reshapes the incentive for investors, developers, and communities.

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

House Speaker Mike Johnson’s July 3 floor announcement that H.R. 1—the “One Big Beautiful Bill”—had passed the House, followed by President Trump’s July 4 signing ceremony, open this special live Fourth of July episode of The Opportunity Zones Podcast. Host Jimmy Atkinson, joined by Andy Hagans, reacts in real time to the unexpected speed with which Opportunity Zones 2.0 became law, permanently embedding the incentive in the tax code.

Jimmy recalls widespread uncertainty just one year earlier. Although OZs enjoy bipartisan appeal, many observers viewed them as a “Trump program,” so renewal hinged on Republican control. Even Washington insiders predicted action no earlier than late summer. Instead, Congress moved in record time: the Senate introduced its final text on June 16 2025, amended it on June 28, passed it 51-50 on July 1 (Vice President J.D. Vance breaking the tie), and the House followed 48 hours later with a 218-214 vote. Trump’s Independence Day signature made OZ 2.0 official—“groundbreaking” and “revolutionary,” as Andy puts it.

Jimmy explains that the current round of zones still sunsets on 12/31/26, but the policy itself is now permanent. New OZ designations will occur every ten years, beginning July 1 2026, with each new map taking effect on January 1 of every year ending in “7” (2027, 2037, 2047, and so on). Andy predicts OZs will become “the next 1031 exchange,” a default pillar of real-estate tax planning.

Key OZ 2.0 Provisions

  • Permanent program framework with decennial zone selection.
  • New deferral schedule and basis step-up for post-12/31/26 investments: a universal five-year deferral and automatic 10 percent basis increase at the five-year mark.
  • Rural incentives: a 30 percent basis step-up and a reduced 50 percent substantial-improvement requirement for existing buildings in rural OZs.
  • Expanded reporting requirements that finally cleared Senate parliamentarian review, promising greater transparency for funds and investors.
  • Narrower eligibility criteria that tighten the definition of a “low-income community,” eliminating the contiguous-tract carve-out and reducing the number of qualifying tracts by roughly 22 percent.

Andy notes that stricter reporting and tighter zone selection may make the program “a tiny bit less flexible,” yet they strengthen bipartisan durability by bolstering social-impact credibility. Jimmy agrees, arguing these changes address critics who questioned the original map’s handful of affluent tracts.

The hosts also flag several issues:

  • 2026 “dead zone.” Investors with 2026 gains may postpone OZ investing until 2027 to capture the new five-year deferral and 10 percent step-up, leaving little incentive to invest during 2026.
  • No retroactive relief. The bill does not extend deferral for pre-2025 investments; the 12/31/26 recognition date remains.
  • Industry wish-list items omitted—non-gains dollars, feeder funds, interim-gain relief, easier operating-business rules, and broader affordable-housing incentives—were deemed too costly and left out.

Looking forward, Jimmy identifies two immediate action areas:

  1. Community advocacy for OZ designation. States may begin selecting tracts on July 1 2026 and can choose only 25 percent of eligible low-income census tracts. Communities should start cultivating relationships with their governors’ offices now to secure a spot on the 2027 map.
  2. Fund compliance preparation. New reporting begins with 2027 tax returns. Funds must gear up for additional data collection—likely on Form 8996—well before then.

Jimmy expects an unofficial new map by October 2026 (90-120 days after the July 1 start), with the Treasury-approved map finalized late in the year. Meanwhile, OpportunityZones.com is hosting a July 15 OZ Insiders master class led by Jim Lang to dive deeper into the statute.

The episode closes with celebratory energy: subscriber counts are soaring, industry momentum is “at an 11,” and both hosts echo Ashley Tyson’s mantra of “doing well by doing good.” Jimmy grades the OZ section of H.R. 1 a solid “A,” calling it “a huge win for investors, developers, and communities all around the country.” Andy thanks Jimmy for the historic livestream and underscores that Opportunity Zones now have something for “both sides of the aisle” to cheer.

Other Discussion Points

  • Initial reactions to the lightning-fast passage of H.R. 1 and what “permanent” really means for OZs.
  • Step-by-step timeline: June 16 Senate text release → June 28 amendment → July 1 Senate passage (51-50) → July 3 House passage (218-214) → July 4 presidential signing.
  • Universal five-year deferral and 10 percent basis step-up for post-2026 investments.
  • Special rural incentives: 30 percent basis boost and 50 percent substantial-improvement threshold.
  • Expanded reporting rules and tighter zone-qualification standards.
  • Potential 2026 investment lull and other unresolved industry priorities.
  • Preparing communities for the 2026-2027 designation cycle and funds for new compliance obligations.
  • Long-term vision: Opportunity Zones as “the next 1031 exchange” and a durable bipartisan tool.

Legislative Timeline

  • 5/22/2025 – House passes H.R. 1 which would renew Opportunity Zones through 2033.
  • 6/16/2025 – Senate releases amended H.R. 1, which would renew Opportunity Zones permanently.
  • 6/28/2025 – OZ 2.0 language modified further to include rolling 5-year deferrals.
  • 7/1/2025 – Senate passes H.R. 1, 51-50 (with VP Vance breaking the tie).
  • 7/3/2025 – House passes H.R. 1, 218-214.
  • 7/4/2025 – President Trump signs bill into law during Independence Day ceremony.

Next Milestones to Watch

  • 7/1/2026 – States begin determining new OZ tracts for a 90-120 day period.
  • 10/29/2026 (approx.) – Unofficial OZ 2.0 map expected.
  • 12/28/2026 (approx.) – Official OZ 2.0 map expected.
  • 1/1/2027 – New zones become active; first investments under new rules begin.
  • 2027 Tax Season – Enhanced fund reporting takes effect.

Stay tuned to OpportunityZones.com for deeper dives into each provision, plus ongoing coverage as the industry gears up for OZ 2.0.