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Published Federal Guidance

IRS Notice 2025-50 lowers the substantial-improvement threshold to 50% in fully rural Opportunity Zones

Opportunity Zone Invest: OZ 2.0 News

Treasury and the IRS issued Notice 2025-50 on Sept. 30, 2025 (IR-2025-96). It defines "rural area" (any area other than a city or town with a population over 50,000 and any urbanized area contiguous and adjacent to such a city or town) and confirms that, effective July 4, 2025, property in a current (2018) Qualified Opportunity Zone comprised entirely of a rural area is substantially improved when additions to basis exceed 50% of its adjusted basis over the 30-month period, instead of 100%. The notice identifies 3,309 of the 2018 zones as entirely rural. It does not cover the new OZ 2.0 nomination round.

Sources

Original reporting by the Opportunity Zone Invest Editorial Team for Opportunity Zone Invest, an independent OZ 2.0 research site. Facts are drawn from the primary sources cited above per our editorial standards. Nothing here is tax, legal, or investment advice. Found an error? See our corrections policy or write to Opportunity Zone Invest.

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