The List of 2027 Opportunity Zone Eligible Tracts

The IRS has published its official list of census tracts eligible for nomination as 2027 Qualified Opportunity Zones — and the clock is now ticking for states to act. Jimmy Atkinson and Andy Hagans break down Revenue Procedure 2026-14, walk through the OZ 2.0 nomination calendar, and explain what developers, fund sponsors, and investors should be doing right now to advocate for their census tracts before the July 1 nomination window opens.

Plus, Jimmy and Andy recap the recent OZ Insiders networking dinner in New York City, share updates on the upcoming Masterclass calendar, and highlight Frances Kern Mennone’s OZ 2.0 State Designation Tracker and Capital Square’s successful refinancing of the Maeve in Downtown Raleigh.

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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

The IRS has officially published the list of census tracts eligible for nomination as 2027 qualified opportunity zones, releasing it in April 2026 via Revenue Procedure 2026-14. Jimmy notes that he, Novogradac, and EIG had each independently crunched the data back in January, and the lists they came up with were identical to the one the IRS ultimately produced.

Of the more than 85,000 census tracts across the United States, the IRS has determined that approximately 25,332 meet the new low-income community definition for opportunity zone designation in 2027. The data set used is the 2020 through 2024 American Community Survey. These designations will officially go into effect on January 1, 2027.

The OZ 2.0 Nomination Calendar

The nomination window opens on July 1 and remains open for 90 days, with each state allowed to request a 30-day extension — which the IRS has indicated it will most likely grant. That pushes the deadline for states out to October 28. Following receipt of nominations, the IRS has a 30-day period to certify the designations, extendable by an additional 30 days, putting the last possible date for the official certified list from Treasury at December 27, 2026.

A Notable Surprise in Rev Proc 2026-14

While no individual census tract caught Jimmy off guard, one notable feature of Revenue Procedure 2026-14 stands out: unlike in 2018, when the IRS published its list and said “this is it,” this time the IRS acknowledges dataset limitations and has outlined a procedure through which a state can nominate a census tract not on the official list. Per the rev proc, the Secretary of the Treasury will consider a state’s nomination of a population census tract not listed in the appendix, provided the state supplies good reasoning.

Jimmy and Andy also flag a piece of unfortunate news for Puerto Rico: due to a technicality in how Puerto Rico’s OZ 1.0 tracts were originally designated, those tracts are set to expire in 2027 — a year earlier than the majority of OZ 1.0 tracts nationwide, which expire in 2028.

What Developers and Investors Should Do Right Now

Jimmy addresses the most common question he’s fielding — what should a developer, fund sponsor, or investor be doing today if they want their census tract nominated as an OZ 2.0 zone. His guidance:

Step one is identifying the person at your state responsible for the OZ nomination process. OpportunityZones.com maintains a page for every state listing the department handling opportunity zones. Step two is building a local coalition — going to your city, county, or economic development authority to get them on board and have them amplify your voice to the state. The goal is a public-private partnership that demonstrates support from investors, developers, and the relevant public authorities together. Jimmy emphasizes not waiting until July 1, noting that many states are already ready to hear from constituents.

For most states, the nomination cap is 25% of their eligible low-income census tracts. States with fewer than 100 eligible tracts get to nominate exactly 25; states with fewer than 25 eligible tracts — such as Vermont and Wyoming — get to nominate all of them.

State Readiness: A Mixed Picture

Jimmy shares data from Frances Kern Mennone’s OZ 2.0 State Designation Tracker, a resource she has been circulating across the OZ industry and sharing with OZ Insiders members. As of April 24, only 17 of the 56 U.S. jurisdictions — all 50 states, the District of Columbia, Puerto Rico, Guam, American Samoa, the Commonwealth of the Northern Mariana Islands, and the U.S. Virgin Islands — have published guidance on OZ 2.0. At least 25 states have named contacts for the nomination process, but 27 jurisdictions have not published anything, encompassing approximately 40% of all projected OZ 2.0 zones.

OZ Insiders New York City Dinner Recap

Jimmy and Andy recap the recent OZ Insiders members-only networking dinner in New York City — the first time the group has hosted an event there. Approximately 30 people attended, with members traveling in from California, Florida, Texas, Connecticut, New Jersey, and Buffalo. Andy notes that the evening included both socializing and active business conversations, describing the energy in the room as positive and exciting. The dinner was planned by Angela Hwang. OZ Insiders has now hosted approximately eight dinners across cities including LA, Dallas, Fort Worth, Park City, Chicago, DC, and Las Vegas, and has recently crossed the 100-member mark.

Upcoming dinners include LA in June or July, Dallas or Fort Worth in September, and Washington DC on October 28 — the night before the Novogradac conference on October 29–30.

OZ Insiders Masterclass Calendar

OZ Insiders hosts monthly online meetings featuring networking, group coaching, and a Masterclass taught by an industry expert. Last month’s Masterclass was taught by Gerry Reihsen, covering how to structure an OZ project to receive capital from two channels simultaneously: direct investors into the project’s fund, and captive QOFs needing to deploy capital at the project level.

Coming up on Monday, May 11, Graham Allison will lead a class on creating unique opportunity zone capital stacks, including layering OZ equity with other tax credits and local and state tax incentives. In June, the class will focus on OZ 2.0 designation guidance, described as highly timely given the nomination calendar. Later in the year, planned topics include rural development, raising capital in the OZ 2.0 era, and analyzing the new OZ 2.0 map — tentatively scheduled for November or December depending on how the designation process unfolds.

Picks of the Month

Jimmy’s pick: Frances Kern Mennone’s OZ 2.0 State Designation Tracker, a PDF document now in its third issue, titled the “2026 National OZ Designation Status Update.” It tracks all 56 U.S. jurisdictions and their progress on OZ 2.0 nomination guidance.

Andy’s pick: A shout-out to Capital Square, sourced via Jill Homan’s Opportunity Zones Outlook newsletter. Capital Square has refinanced the Maeve, a 297-unit mixed-use development in a Downtown Raleigh opportunity zone. Construction began in 2022, and the project was completed in December 2023. Jimmy and Andy both highlight the significance of OZ 1.0 success stories like this one, noting that successful refinancings help build excitement for the next round of opportunity zones.