Tools · For QOF and QOZB managers

Opportunity Zone substantial improvement test calculator

Updated · Free, no sign-up, runs in your browser

If a Qualified Opportunity Fund buys a building that was already in use in the zone, the building counts as qualified property only if the fund substantially improves it: within any 30-month period beginning after it was acquired, additions to the building's basis must exceed its adjusted basis at the start of that period (IRC §1400Z-2(d)(2)(D)(ii); Treas. Reg. §1.1400Z2(d)-2(b)(4)(i)). In a zone comprised entirely of a rural area, the bar is 50% of that basis (P.L. 119-21, §70421(c)(4)(C)).

Related: QOZB test checker (70% tangible property, 31-month working capital safe harbor) · Census tract lookup (shows which OZ 2.0-eligible tracts are rural).

The building
Result
Substantial improvement target (100% test)
$772,500
Add more than $772,500 to the building's basis by September 15, 2029.
Your plan of $800,000 passes.
Building's adjusted basis
$772,500
At the start of the 30-month period, land excluded.
30-month deadline
Sep 15, 2029
Period runs March 16, 2027 to September 15, 2029.
Even spending pace
$25,750/mo
Target ÷ 30 months.
Your plan
Passes
$800,000 exceeds $772,500.

How this was calculated

  1. Land: 25% × $1,000,000 = $250,000. Land is excluded: the test measures additions to the building's basis, and the land doesn't have to be separately improved (Treas. Reg. §1.1400Z2(d)-2(b)(4)(iv)(A), (E)).
  2. Building cost: $1,000,000 − $250,000 = $750,000. Capitalized costs are split in the same ratio: $30,000 × 75% = $22,500.
  3. Starting basis: $750,000 + $22,500 − $0 depreciation = $772,500.
  4. Threshold: $772,500 × 100% = $772,500. Additions must exceed it, so spending exactly $772,500 isn't enough.
  5. Deadline: 30 months from March 16, 2027 is September 15, 2029 (the last day of the period). Pace: $772,500 ÷ 30 = $25,750 a month.

Estimates only; not tax advice. Allocating price between land and building, deciding what counts as an addition to basis, and the aggregation rules all depend on your facts. Your inputs stay in your browser.

The rules, with sources

  • The test. Property is substantially improved "only if, during any 30-month period beginning after the date of acquisition of such property, additions to basis with respect to such property in the hands of the qualified opportunity fund exceed an amount equal to the adjusted basis of such property … at the beginning of such 30-month period" (IRC §1400Z-2(d)(2)(D)(ii)). The regulations repeat it as the "substantial improvement requirement" (Treas. Reg. §1.1400Z2(d)-2(b)(4)(i)). Because additions must exceed the basis, the calculator treats spending exactly the threshold as a fail.
  • Buildings, not land. For a building on land in a QOZ, the test is measured by additions to the building's basis (§1.1400Z2(d)-2(b)(4)(iv)(A)), and the land under it doesn't have to be separately improved ((b)(4)(iv)(E)). Unimproved land doesn't have to be substantially improved ((b)(4)(iv)(B)), unless it's bought with no intention of improving it by more than an insubstantial amount within 30 months ((b)(4)(iv)(C)).
  • Rural zones: 50%. P.L. 119-21 inserted "(50 percent of such adjusted basis in the case of property in a qualified opportunity zone comprised entirely of a rural area …)" into §1400Z-2(d)(2)(D)(ii) (§70421(c)(4)(C)). That amendment "shall take effect on the date of the enactment of this Act", which was July 4, 2025 (§70421(c)(5)(C)).
    • 2018 zones (OZ 1.0): IRS Notice 2025-50 applies the 50% threshold "for any determination made on or after July 4, 2025" (section 5) to the 3,309 2018 QOZs it lists in its Appendix as comprised entirely of a rural area (section 3).
    • 2027 zones (OZ 2.0, designated January 1, 2027 to December 31, 2036): Rev. Proc. 2026-14 identifies 25,332 eligible tracts, 8,334 of them comprised entirely of a rural area (section 3.01), in its Appendix.
    • "Rural area" means any area other than a city or town with more than 50,000 inhabitants and any urbanized area contiguous and adjacent to such a city or town (IRC §1400Z-2(b)(2)(C)(ii), added by §70421(c)(2)). Notice 2025-50 section 4 explains how Treasury applies it using 2020 Census data.
  • When you don't need the test at all. If original use in the zone starts with the fund (for example, new construction not yet placed in service), the property meets the original-use requirement instead (§1.1400Z2(d)-2(b)(3)(i)(A)). Real property that was vacant for at least one uninterrupted calendar year before the zone's designation, or for three uninterrupted calendar years after it, and still vacant at purchase, also starts original use with the buyer ((b)(3)(i)(B)). Vacant means more than 80% of the usable square footage isn't in use ((b)(3)(iii)).
  • Not modelled here: counting newly bought equipment that improves the building's functionality ((b)(4)(iii)), treating several buildings as one property ((b)(4)(v)), and how the 30-month period interacts with the working capital safe harbor (Treas. Reg. §1.1400Z2(d)-1).

Worked examples

1. Urban building

A QOF buys a building for $1,000,000 on March 15, 2027, with 25% of the price allocated to land, and $30,000 of capitalized closing costs. Building cost is $750,000, and its share of closing costs is $22,500 (75% of $30,000), so the starting basis is $772,500. The fund must add more than $772,500 to the building's basis in the 30-month period running March 16, 2027 to September 15, 2029, about $25,750 a month. A plan of $800,000 passes.

2. Building in an entirely rural 2018 zone

A $400,000 purchase on November 2, 2026 with 30% allocated to land gives a $280,000 building basis. At 50%, additions must exceed $140,000 by May 2, 2029 (period starting November 3, 2026). A $100,000 plan falls short: you'd have to add more than $40,000.

3. The Treasury regulation's hotel example

A QOF buys a hotel for $5,000,000, with $1,000,000 allocated to land and $4,000,000 to the building, furniture and fixtures. The regulation concludes the fund "must expend $4 million to improve the hotel within the 30-month substantial improvement period" (Treas. Reg. §1.1400Z2(d)-2(b)(4)(iii)(D), Example 1). With a $5,000,000 price, 20% land and no other costs, the calculator returns the same $4,000,000.

FAQ

What is the Opportunity Zone substantial improvement test?

A building a QOF (or a QOZ business) buys that was already used in the zone qualifies only if, during any 30-month period beginning after the date it was acquired, additions to its basis exceed its adjusted basis at the start of that period (IRC §1400Z-2(d)(2)(D)(ii); Treas. Reg. §1.1400Z2(d)-2(b)(4)(i)). In practice, you roughly double your basis in the building within 30 months. Not tax advice.

Does the land count toward the basis that must be doubled?

No. For a building on land in a QOZ, the test is measured by additions to the basis of the building, and the land does not have to be separately improved (Treas. Reg. §1.1400Z2(d)-2(b)(4)(iv)(A) and (E)). Unimproved land generally does not have to be substantially improved at all (§1.1400Z2(d)-2(b)(4)(iv)(B)), unless the land is bought with no intention to improve it by more than an insubstantial amount (§1.1400Z2(d)-2(b)(4)(iv)(C)).

Is the threshold 50% in rural areas?

Yes, for property in a QOZ comprised entirely of a rural area. P.L. 119-21 §70421(c)(4)(C) added the 50% rule to IRC §1400Z-2(d)(2)(D)(ii), effective on enactment, July 4, 2025 (§70421(c)(5)(C)). Notice 2025-50 applies it to determinations made on or after July 4, 2025 for the 3,309 2018 QOZs it lists as entirely rural. For 2027 zones, Rev. Proc. 2026-14 flags which eligible tracts are comprised entirely of a rural area.

Is the 50% rural rule only for OZ 2.0?

No. Unlike the 30% rural step-up, which applies only to amounts invested after December 31, 2026, the 50% substantial improvement rule took effect July 4, 2025 and covers property in existing 2018 zones that are entirely rural (Notice 2025-50, sections 2.03 and 5).

Does a new building or a long-vacant building need to be substantially improved?

Not if original use in the zone starts with the QOF or QOZ business. Property not previously placed in service in the zone meets original use (Treas. Reg. §1.1400Z2(d)-2(b)(3)(i)(A), (C)). Real property vacant for at least one uninterrupted calendar year before the zone was designated, or for three uninterrupted calendar years after, and still vacant at purchase, also qualifies (§1.1400Z2(d)-2(b)(3)(i)(B)); "vacant" means more than 80% unused (§1.1400Z2(d)-2(b)(3)(iii)).