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Summary and initial thoughts — Changes to opportunity zones (OZs)

Jun 19, 2026 · 1 min read

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H.R. 1, P.L. 119-21, the law known as the One Big Beautiful Bill Act (OBBBA), fundamentally revises the Opportunity Zone (OZ) program, specifically enhancing rural incentives and defining a rural area. This resource aims to clarify questions that may arise regarding changes to the OZ regime that take effect for the tax years beginning on or after July 4, 2025.

On June 18, 2026, Treasury and the IRS announced in Notice 2026‑40 the plan to issue proposed regulations on qualified

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