01
A Continuing Program
OZ 2.0 replaces a one-time designation with a recurring cycle. The next cycle is described in the working materials as running from January 1, 2027 through December 31, 2036.
Federal Opportunity Zones
Opportunity Zones 2.0
A general summary of the federal Opportunity Zone rules as amended, as they are expected to apply to investments made on or after January 1, 2027. Not tax advice. Final statutes, regulations, and designations control.
At a General Level
What OZ 2.0 Changes
The One Big Beautiful Bill Act (OBBBA), signed July 4, 2025, amended the federal program. This page stays at that altitude — not a code walkthrough.
02
No All-Island Map
The blanket designation of eligible low-income tracts in Puerto Rico is gone. New tracts are capped — up to 25% of eligible low-income community tracts, with a floor and a rural set-aside. A 2026 zone does not guarantee a 2027 zone.
03
Earlier Puerto Rico Sunset
Legacy Puerto Rico QOZs are scheduled to sunset December 31, 2027 — earlier than the sunset described for original tracts in the 50 states. The working draft does not rely on original-program tract status for capital deployed after 2026.
Planning Summary — Not Tax Advice
The Shape of the Federal Benefit
For qualifying capital gains invested in a QOF on or after January 1, 2027, the working summary describes three features. Percentages and timing are planning language only.
Rolling Deferral
Recognition of eligible gain may be deferred for five years from the date of the investment, rather than to one fixed calendar date.
Basis Step-Up
After five years, a basis step-up is described: 10% generally, and 30% where a rural qualified opportunity fund applies. Rural treatment is tract-specific and is not assumed, including in the San Juan metro.
Longer-Hold Exclusion
After at least ten years, an election to exclude gain on the QOF interest is described, with an outer limit of 30 years on that exclusion.
Nothing here is tax, legal, or investment advice. Treatment depends on the investor, timing, ongoing fund compliance, and future Treasury, IRS, and Puerto Rico guidance. The Fund is an intended QOF; the Fund LP is not yet formed.
In Underwriting
Tract First. Economics First.
Eligibility is a tract-level determination. Island location is not zone coverage. Each investment is expected to document the census tract, whether it is an original-program tract or an OZ 2.0 tract, and written tax-counsel confirmation before closing.
No investment is approved only because it is inside an eligible tract. It still has to show financial viability and credible local demand. Tax benefits are not a substitute for project economics.
From PPM §§3.1 and 3.5 and the investor-deck risk line. Blind pool — no named assets.
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Puerto Rico Growth & Resilience Fund I is live. Accredited investors may request information.
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