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.
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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.