The Business, Entrepreneurship & Tax Law Review

Article Title

Good Enough: How Minimal IRS Guidance is Sufficient to Navigate §1400Z Opportunity Zones


Riley Coy


Subchapter Z, as part of the Tax Cuts and Jobs Act, creates “Opportunity Zones” which provide investors with a tax incentive to invest their realized capital gains in certain distressed neighborhoods. The goal of this subchapter is the economic growth of these communities. As described below, the language of subchapter Z is subject to interpretation in certain respects. Subsequently, the IRS issued a proposed regulation to provide guidance and clarity to the ambiguities within the language. Although many issues still remain unresolved, the guidance provided is a significant step in the right direction.