
Opportunity Zones 2.0: What Investors Need to Know About the New Tax Law (2025 Update)
The Opportunity Zones program has undergone a major transformation with new legislation that permanently extends and enhances this powerful tax deferral strategy. High net worth investors and real estate professionals should understand these changes to maximize their tax benefits and investment returns. In the latest episode of Peachtree Point of View, Peachtree Group CEO Greg Friedman sits down with Jason Watkins, partner at Novogradac and Opportunity Zones expert, to break down recent game-changing legislation.
Opportunity Zones 2.0: What Changed in the New Law
Permanent Extension Creates Long-Term Planning Opportunities
With the new legislation signed into law on July 4, 2025,Opportunity Zones became permanent. Unlike the original program's limited timeline, OZ 2.0 creates rolling 10-year cycles with new zone designations every decade, giving investors the confidence to use this as a long-term tax planning tool rather than a one-time opportunity.
Five-Year Capital Gains Deferral for New Investors
In the new version of the law, there is a critical timing consideration that investors should understand. The new five-year deferral benefit, where every investor gets five years to defer capital gains taxes regardless of when they invest, only applies to investments made after December 31, 2026. Current investors are still locked into the 2026 recognition date, making strategic timing crucial for tax planning.
Rural Opportunity Zones Offer Enhanced Tax Benefits
Here's where savvy investors can maximize their tax advantages: investments in rural Opportunity Zones now receive a 30% basis step-up compared to just 10% for standard zones. This represents a massive tax incentive that could redirect capital flows and create significant opportunities for investors willing to explore rural markets.
Fewer Qualified Zones Mean More Competition
The new law tightens eligibility criteria from 80% to 70% of median family income, potentially reducing the total number of Opportunity. Zones by approximately 20%, from 8,764 to about 7,000 zones nationwide. This reduction means increased competition for quality investment opportunities.
Key Takeaways from this Episode
- Timing matters: Current investments face 2026 tax recognition; post-2026 investments get five-year deferrals
- Rural advantage: 30% basis step-up for rural zones vs. 10% for standard zones creates compelling risk-adjusted returns
- Zone reduction: Approximately 20% fewer eligible zones mean increased competition for quality opportunities
- Permanent program: Rolling 10-year cycles provide long-term planning certainty
- Downside protection: Pay taxes on the lesser of original deferred gain or current fair market value
With commercial real estate values down an average of 20% from their peak and some sectors like office down 40% or more, the timing and structure of this correction could create compelling investment opportunities.
Don't miss the full conversation where Jason and Greg dive deeper into implementation timelines, rural zone definitions, and specific strategies for maximizing these benefits.
Listen to the complete episode of Peachtree Point of View on your favorite podcast platform and subscribe for regular updates on investment opportunities, market trends, and strategies that help sophisticated investors optimize their portfolios.

Please note that this podcast does not provide legal or tax advice. Before investing in any tax-advantaged program, consult with your CPA or a tax attorney to ensure you are eligible to benefit from the program's tax advantages.

Every Move Matters: Navigating the New Era of Commercial Real Estate
You don't think twice about skipping a workout or hitting snooze, until six months later when your back goes out lifting a suitcase. That's the thing about choices: they rarely shout. Most whisper. At the moment, they feel light, harmless, and even forgettable. But over time, they stack up and eventually shape everything.
It's the same in commercial real estate.
For years, the market rewarded financial engineering. Falling interest rates, cap rate compression and cheap capital allowed many investors to ride the momentum and still generate strong returns. That era is over.
We're now operating in a higher-for-longer environment. Interest rates are elevated, traditional lenders have pulled back, and capital markets are volatile. Macroeconomic disruptions, geopolitical risk and inflation-shifting trading policy are repricing risk in real time.
In this environment, every move matters. Every decision, whether to buy, sell, recapitalize or hold, carries more weight than it did even a year ago.
· Capital must be deployed with precision. The margin for error has narrowed. Mispricing risk, overleveraging,or relying on optimistic underwriting can quickly impair a deal.
· Liquidity is a strategic advantage.In a market where many lenders have pulled back or lowered leverage, execution certainty is no longer assumed. It's earned.
· Fundamentals, not financial engineering, define success. Cap rate compression is no longer the tailwind it once was. Returns must come from operational excellence, asset quality and disciplined management.
· Time is costly. In action can be just as damaging as a poor decision. Delays in refinancing or hesitation in uncertain markets can weigh heavily on performance.
At Peachtree, we've built our platform for this exact environment. With a fully integrated investment and credit platform, deep experience across market cycles, and flexible capital ready to deploy, we're well-positioned to take decisive action when others hesitate.
Because in this market, as inlife, every action has a weight and the most successful outcomes are born from clarity, discipline and conviction.
Private credit remains one of the most compelling solutions in today's market, offering downside protection, yield and flexibility. And with traditional capital still constrained, special situation investing is gaining momentum as a primary strategy to unlock value in a dislocated market.
As the landscape evolves, we continue to seek opportunities that leverage our strengths and provide value to our investors.
— Greg Friedman | Managing Principal & CEO of Peachtree Group
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Peachtree Group CEO Recognized as 2025 Industry Leader in Commercial Real Estate Finance
ATLANTA (May 5, 2025) - Peachtree Group (“Peachtree”) is proud to announce that Greg Friedman, managing principal and CEO, has been recognized among the 2025 Rainmakers in CRE Debt, Equity & Finance by GlobeSt.,and named to Commercial Observer’s prestigious Power Finance list. These industry-leading accolades highlight Friedman's exceptional leadership, strategic innovation and enduring impact on the commercial real estate finance landscape.
Inclusion on the GlobeSt. Rainmakers list acknowledges Friedman's ability to navigate one of the most challenging commercial real estate finance periods. Amid elevated interest rates, tightening capital markets and declining valuations, Friedman has led Peachtree's vertically integrated management platforms with clarity and conviction. His approach has helped stakeholders unlock value, access liquidity and capitalize on market dislocation.
Commercial Observer’s Power Finance list further affirms Friedman’s influence and adaptability. As lenders retracted and transaction volume slowed, Peachtree continued to deliver creative capital solutions from originating loans to establishing strategic partnerships and playing across the capital stack. Under Friedman’s leadership, Peachtree has remained a dependable partner known for its certainty of execution, critical expertise and a solutions-driven mindset.
“These recognitions are a testament to Greg’s vision and our entire team’s commitment to being a steady force in an unpredictable market,” said Jatin Desai, managing principal and CFO of Peachtree. “Our strategy has always centered on disciplined investing, innovation and building strong relationships. Greg has set the tone.”
Peachtree’s success is powered by a high-performing, deeply experienced team that brings together the full spectrum of credit, equity, development and asset management expertise. This collective strength allows the firm to respond decisively to market shifts, underwrite with conviction and deliver solutions others can’t.
Peachtree has executed over $12 billion in commercial real estate transactions since inception. Its integrated platform aligns real estate, credit and capital markets expertise, positioning the firm to identify opportunities, deploy capital efficiently and manage risk across cycles.

Peachtree Group Closed 15 Loans Totaling $335MM in the Last 90 Days
Explore Peachtree Group's latest commercial loan transactions and financing options.
Peachtree Group is a direct balance sheet lender focused on funding first mortgage loans. Our areas of expertise include:
- Bridge loans
- Mezzanine loans
- Preferred equity investments
- Commercial property assessed clean energy (CPACE) financing
We lend to all commercial real estate asset classes and are actively providing financing for:
- Acquisitions
- Recapitalizations
- Construction projects
See below for some of the most recent loan transactions from Peachtree Group, including:
- Hotel loans
- Retail properties
- Multifamily developments
- Industrial assets
- Land deals
Need Financing? Contact us at lending@peachtreegroup.com.

Peachtree Group Closed 15 Loans Totaling $335MM in the Last 90 Days
June 2025 highlights

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