We develop institutional-grade commercial and multifamily properties in Qualified Opportunity Zones — deploying capital gains into high-yield real estate while delivering powerful federal tax advantages to investors.
Qualified Opportunity Zones (QOZs) were established by Congress under the Tax Cuts and Jobs Act of 2017 to spur private investment into economically distressed communities across the United States. Over 8,700 census tracts in all 50 states, the District of Columbia, and U.S. territories have been designated as Opportunity Zones.
The mechanism is straightforward: investors who realize capital gains from any source — stocks, real estate, business sales — can defer and ultimately eliminate federal tax on those gains by reinvesting into a Qualified Opportunity Fund (QOF) within 180 days.
Unlike a 1031 exchange, which only defers taxes, Opportunity Zone investments can permanently eliminate capital gains tax on appreciation if the investment is held for 10 or more years. This makes the OZ program among the most powerful tax-advantaged real estate investment vehicles in U.S. history.
"The program's ability to deploy private capital for public revitalization — without direct government subsidy — represents a structural shift in how distressed communities can attract institutional investment."
Investors have 180 days from the realization of any capital gain — from stocks, real estate, or business sales — to roll proceeds into a Qualified Opportunity Fund and defer tax liability.
Investors who hold their QOF investment for at least 5 years receive a 10% reduction of the originally deferred capital gains tax liability, permanently reducing what is owed.
The defining benefit: investors who hold for 10+ years pay zero federal capital gains tax on all appreciation generated within the Opportunity Fund. Growth is tax-free.
The original Tax Cuts and Jobs Act is set to sunset December 31, 2026. Investors who want to access the full benefit package must act now. The 10-year clock begins at investment.
We focus on value-creation through ground-up construction and substantial rehabilitation in established Opportunity Zone markets — targeting commercial and multifamily assets with strong fundamentals, durable demand, and deep local market knowledge.
New construction of Class A and workforce multifamily communities in high-demand OZ markets. We target submarkets with population growth, supply constraints, and strong employment drivers. Projects are structured to qualify for permanent agency financing (Fannie Mae, Freddie Mac, HUD) upon stabilization.
Ground-up and adaptive reuse of commercial assets combining retail, office, and residential components. Mixed-use projects in OZs benefit from urban revitalization dynamics, anchor tenant credit, and value-add repositioning potential. We specialize in infill sites with entitlement certainty.
For projects in deeply distressed OZ tracts, we structure stacked capital solutions combining Low-Income Housing Tax Credits (LIHTC), HUD 221(d)(4) construction/permanent financing, and QOF equity. This layered approach enables development that market-rate capital alone cannot support.
Ground-up industrial, warehouse, and flex-commercial development in OZ-designated industrial corridors. Strong demand fundamentals from e-commerce, last-mile logistics, and reshoring trends make OZ industrial highly competitive on a risk-adjusted basis. Triple-net lease structures provide income certainty.
Acquisition and substantial rehabilitation of existing structures in QOZ tracts, where the developer must invest capital equal to or exceeding the property's basis within 30 months. Rehab projects offer faster delivery timelines than ground-up and can qualify for Historic Tax Credits (HTC) where eligible.
We partner with local operators, landowners, and regional developers to execute OZ deals that require co-GP alignment, capital stack advisory, or QOF structuring expertise. Our platform provides QOF formation, investor relations, and compliance oversight for joint venture partners.
Reinvest capital gains within 180 days of realization and defer federal tax on those gains until December 31, 2026. Available for gains from stocks, real estate, business sales, and other assets.
Holding the QOF investment for at least 5 years permanently reduces the original deferred gain by 10%, reducing the taxable amount when recognition occurs in 2026.
The most powerful benefit: all appreciation earned within the Opportunity Fund itself is permanently excluded from federal capital gains tax upon a qualifying sale after a 10-year hold.
QOZ equity can be structured alongside LIHTC (4% & 9%), Historic Tax Credits, and HUD financing, creating compounding tax-advantaged yields unavailable through any single program.
Unlike 1031 exchanges (real estate only), OZ investments accept capital gains from equities, cryptocurrencies, business interests, and other assets — dramatically expanding the eligible investor universe.
Every OZ investment directs private capital into federally certified distressed communities — generating construction jobs, housing supply, and long-term economic revitalization. Measurable ESG outcomes are documented through economic impact studies.
Consider an investor with $1,000,000 in capital gains from a stock sale. Here is how the OZ benefit compares to a standard taxable reinvestment — held for 10 years at an assumed 8% annual return.
This scenario is illustrative only. Actual tax outcomes depend on individual circumstances. Consult your tax advisor before investing. Returns are not guaranteed.
Investor realizes a capital gain from any eligible source — equities, real estate, business interest, or other assets. The 180-day reinvestment clock begins at recognition.
A Qualified Opportunity Fund (QOF) is self-certified via IRS Form 8996. The QOF must maintain 90% of assets in Qualified Opportunity Zone property, tested semi-annually.
QOF capital is invested into a Qualified Opportunity Zone Business (QOZB). The QOZB acquires and develops real property within a designated census tract, meeting the substantial improvement test.
Ground-up construction or substantial rehabilitation is completed. The asset is leased, stabilized, and managed through a hold period designed to maximize both operating income and exit value.
At or after the 10-year mark, the QOF liquidates the property. All appreciation within the fund is permanently excluded from federal capital gains tax. Investor receives after-tax proceeds at exit.
The original Opportunity Zone program — established under the 2017 Tax Cuts and Jobs Act — was always designed with a sunset clause. That uncertainty limited investor appetite for long-term projects and created a "hibernation" dynamic as 2026 approached. The program's foundational tax benefit — zero capital gains on appreciation after 10 years — was slated to expire in 2047, giving investors little runway.
All of that changed on July 4, 2025, when President Trump signed the One Big Beautiful Bill Act (OBBBA) into law. The legislation makes the Opportunity Zone incentive a permanent feature of the Internal Revenue Code, introduces rolling zone re-designations every decade, creates powerful new incentives for rural investment, establishes new reporting standards, and tightens eligibility criteria to focus investment on the most economically distressed communities.
Importantly, OZ 1.0 and OZ 2.0 operate under separate tracks. Investments made on or before December 31, 2026 are governed by the original rules. Investments made on or after January 1, 2027 operate under the new OZ 2.0 framework with rolling five-year deferral, updated basis step-up schedules, and expanded rural fund benefits.
The passage of OZ 2.0 removes the single greatest barrier to large-scale, long-horizon development deals: program uncertainty. Institutional capital that sat on the sidelines now has a permanent vehicle with IRS-anchored certainty.
The sunset date is eliminated entirely. The Opportunity Zone incentive is now a standing provision of the Internal Revenue Code with no expiration, giving developers and investors the long-term planning certainty needed for large-scale development projects.
Under OZ 1.0, all deferred gains were recognized on December 31, 2026. Under OZ 2.0, any gain invested after December 31, 2026 receives a rolling five-year deferral from the investment date — meaning investors are no longer racing a single deadline.
Beginning July 1, 2026, state governors must re-nominate Opportunity Zone census tracts every 10 years. New OZ 2.0 zones take effect January 1, 2027, with subsequent rounds in 2036 and 2046. The map will reset to reflect current economic data rather than 2018 conditions.
The income qualification threshold drops from 80% to 70% of median family income, and the "contiguous tract" exception is eliminated entirely. Only genuinely distressed census tracts qualify under OZ 2.0 — ensuring investment is targeted at communities with measurable need.
OZ 2.0 introduces mandatory annual reporting requirements for Qualified Opportunity Funds and QOZBs. Enhanced disclosures cover social and economic outcomes — jobs created, housing units delivered, community impact — addressing a major criticism of OZ 1.0's lack of accountability.
OZ 2.0 introduces an automatic basis step-up to fair market value after 30 years — meaning investors who hold beyond 30 years no longer need a qualifying sale to access the tax-free appreciation benefit. This protects long-hold, generational asset strategies.
One of the most significant structural additions in OZ 2.0 is the creation of the Qualified Rural Opportunity Fund (QROF) — a new fund category with materially enhanced tax benefits for investments in rural Opportunity Zone tracts.
Rural areas are defined as any geography outside a city or town with 50,000 or more inhabitants, or urbanized areas contiguous to such cities. QROFs must maintain at least 90% of assets invested in qualified rural OZ property throughout the holding period.
The incentives are substantial: a 30% basis step-up at five years (vs. 10% for standard QOFs) and a reduced 50% substantial improvement threshold — meaning a QROF acquirer needs to invest only $1M in improvements on a $2M property basis, versus $2M under standard rules. This makes rehabilitation economics dramatically more favorable in rural markets.
The 50% substantial improvement threshold for rural QROFs was effective immediately upon signing of the OBBBA on July 4, 2025. Treasury Notice 2025-50 (Sept. 30, 2025) provides guidance on rural area identification.
President Trump signs the One Big Beautiful Bill Act. OZ program made permanent. Rural QROF 50% substantial improvement threshold effective immediately.
Last date to make investments governed by OZ 1.0 rules. Deferred gains under OZ 1.0 must be recognized by this date. Final window to access original 10%/15% step-up schedule.
New OZ 2.0 census tracts take effect. All investments made from this date forward operate under the new rolling deferral, updated step-up schedule, and QROF framework.
The original 2018 OZ census tract designations expire. Active OZ 1.0 investments already in place are grandfathered and continue to operate under original program terms.
The following represents a sample of Opportunity Zone development transactions reflective of our deal experience, asset focus, and geographic strategy.
¹ All transactions listed are illustrative examples presented for informational purposes only. They do not represent actual completed transactions and should not be relied upon as evidence of past performance. Actual deal structures, capital stack composition, and outcomes will vary. This material does not constitute an offer to sell or solicitation of an offer to buy any securities.
From site identification and entitlements through construction management, lease-up, and asset management — we control each stage. Vertical integration reduces execution risk and protects QOF timelines.
We structure and execute multi-source capital stacks combining QOF equity, LIHTC, HUD 221(d)(4), CMBS, tax-exempt bonds, and public subsidy programs. Most OZ developers can't run this playbook.
Investors receive quarterly reporting, audited financials, and IRS Form K-1 support. QOF compliance — including semi-annual 90% asset tests — is managed internally with dedicated tax counsel.
We maintain active deal pipelines in NJ, NY, MD, PA, OH, MI, AL, and AZ markets — with ground-level relationships with landowners, municipalities, and anchor tenants before sites are publicly marketed.
Our principals invest alongside QOF investors in every deal. Co-investment and performance-based promote structures ensure our incentives are 100% aligned with investor capital and returns.
Whether you have a capital gain to deploy, a site in a Qualified Opportunity Zone, or a development project in need of QOF structuring — we want to hear from you. All inquiries are handled with discretion and responded to within 48 business hours.