Opportunity Zone Investing After the One Big Beautiful Bill Act

Gerald J. Reihsen, III, Founding Partner | Reihsen & Associates

Gerald J. (Gerry) Reihsen, III is the founding partner of Reihsen & Associates in Dallas, Texas, where he serves as corporate–securities and Opportunity Zone counsel to investors, sponsors, funds, and operating businesses. Drawing on four decades of combined legal and entrepreneurial experience, he pairs dealmaking instincts with a protective approach to each client’s growth, and he is a nationally recognized Opportunity Zone attorney, speaker, and writer.

• Education & Credentials

Mr. Reihsen earned his JD, cum laude, from the University of Wisconsin-Madison in 1985 and his BA, magna cum laude, from the University of Mississippi in 1982, where he majored in psychology and English literature with a minor in chemistry. He is admitted to practice in Texas and Wisconsin.

• Recognition & Leadership

Mr. Reihsen is a National Association of Corporate Directors (NACD) Board Leadership Fellow, having completed NACD’s program of study for directors and corporate governance professionals. He has composed and served on numerous public company boards, including the Board of Directors of Ashford, Inc. (NYSE MKT: AINC), where he chaired the audit committee.

• Professional Involvement

Mr. Reihsen has founded and served on the boards of several industry trade groups and engages in political, civic, and charitable causes aimed at connecting communities. He chaired the effort to establish Cristo Rey Dallas College Preparatory School and continues to serve on its board, and he is a sought-after speaker and panelist on business, board, and legal topics.

• Experience

Mr. Reihsen’s corporate–securities practice advises investors, funds, and businesses on entity structuring, capital formation, private and public offerings, mergers and acquisitions, complex transactions, and Opportunity Zone transactions, with industry experience spanning leading-edge technology, investment funds and sponsors, family offices, broker-dealers, and real estate enterprises. His practice has included extensive work with direct participation investment programs such as non-listed REITs and Section 1031 investment structures. As an entrepreneur, he co-founded Behringer Harvard Funds and Xybridge Technologies, has built for-profit and nonprofit enterprises, and has raised more than five billion dollars of equity across multiple capital channels.

SESSION 1 – OZ 2.0 After the One Big Beautiful Bill Act: Permanent Benefits, Eligible Gains, and QOZB Compliance | 1:00pm – 2:00pm

This session examines the Opportunity Zone program as remade by the One Big Beautiful Bill Act. Section 1400Z now establishes a recurring national program, pairing five-year deferral and basis increases with tax-free appreciation that can extend through year 30, and OZ benefits can stack with LIHTC, NMTC, historic credits, and other project incentives. The session works through what capital can enter the program—gross capital gain, Section 1231 gain, and Section 1250 depreciation recapture—and the 180day window, including pass-through elections that can extend it. It then turns to compliance: QOZB asset qualification, the five revenue-nexus tests, the 31-month working-capital safe harbor, and Form 8996’s detailed annual reporting. The session closes with 100% bonus depreciation under OBBBA and the architecture of a personal QOF platform.

BREAK | 2:00pm – 2:10pm

SESSION 2 – Opportunity Zones vs. §1031: Choosing the Vehicle, Managing the Transition | 2:10pm – 3:10pm

This session puts Opportunity Zone investment side by side with the Section 1031 like-kind exchange. It compares triggering gains, what is acquired, timing rules, geography, proceeds handling, tax outcomes, basis, treatment at death, and asset universes, then applies the comparison through taxpayer examples— non-real-estate gains, stabilized income property, liquidity retention after a real-estate sale, and value creation. Attendees work through a five-question advisor framework matching the client’s gain, target portfolio, control, liquidity, and legacy plan to the right vehicle, along with capital-recycling guardrails, QOZB working-capital notes, and loss-harvesting strategies that can make a §1031 rollover moot. The session ends with the OZ 1.0 transition: Notice 2026-40’s limits on new OZ 1.0 capital, the mandatory 2026 inclusion, and the Reihsen & Associates comment-letter safeguards.