Rural Opportunity Zones and the New OZ 2.0 Compliance Regime: QROFs, the 2027 Map, and Expanded Fund Reporting

Marc L. Schultz, Partner | Snell & Wilmer

Marc L. Schultz is a partner at Snell & Wilmer in Phoenix, where his practice centers on federal, state, and local taxation, including complex transactions involving corporations, limited liability companies, limited partnerships, tax-exempt entities, and real property. He counsels clients on mergers and acquisitions, joint ventures, private investment fund formation, tax credit financing, and energy transactions. Mr. Schultz chairs the firm’s Tax Credit Finance Group and Renewable Energy Group, and he founded and co-chairs its Opportunity Zones and Funds Industry Group.

• Education & Credentials

Mr. Schultz received his LL.M. in taxation from the New York University School of Law, his J.D., with highest honors, from the Chicago-Kent College of Law, and his B.A.

• Recognition & Leadership

Mr. Schultz serves on the Advisory Board of the Novogradac Journal of Tax Credits. He has been named to AZ Business Magazine’s Top Lawyers in Renewable Energy Law (2013).

• Professional Involvement

Mr. Schultz served as an adjunct professor teaching taxation of business entities in the Graduate Program of Accountancy at the University of Illinois-Chicago, and served on the Board of Directors of the Arizona Housing Finance Authority as an appointee of Arizona Governor Doug Ducey. He is a regular speaker and panelist on tax credit finance and the Opportunity Zone incentive and has written numerous articles and been quoted in numerous publications in these areas.

• Experience

Mr. Schultz currently represents investors, fund sponsors, and developers with respect to the Opportunity Zone incentive, and he was involved in advising on and drafting comment letters submitted to the U.S. Department of the Treasury and the Internal Revenue Service on the Opportunity Zone proposed regulations. He has represented investors, developers, and syndicators in Low-Income Housing Tax Credit transactions and numerous parties in New Markets Tax Credit, Historic Tax Credit, and renewable energy transactions, and he regularly drafts Power Purchase Agreements as part of his renewable energy practice.

Brent Parker, CPA, Partner | Novogradac & Company LLP

Brent Parker is a partner at Novogradac & Company LLP, based in the firm’s Long Beach, California office. His practice centers on affordable housing and community development, with a particular focus on investments in qualified opportunity funds and the low-income housing tax credit, and he works with for-profit and nonprofit organizations on tax-incentivized, real estate-oriented ventures at both the project and fund levels. He also serves private equity commercial and market-rate clients.

• Education & Credentials

Mr. Parker earned a bachelor’s degree in accounting from the University of Southern California and is a certified public accountant licensed in California.

• Recognition & Leadership

Responding to growing demand, Mr. Parker has become a frequent presenter on panels and workshops across several states on a variety of tax credit and community development topics. Within the firm, he leads professional development efforts on complex taxation concepts.

• Professional Involvement

Mr. Parker is a contributor to the Novogradac Journal of Tax Credits and to the Tax Credit Tuesday podcast. His recent writing includes “45L Credit Extension Expands Clean Energy Possibilities for LIHTC Developers” (2023) and “Benefits of the Inflation Reduction Act for Affordable Housing” (2022).

• Experience

Mr. Parker leads extensive tax planning and tax return preparation engagements for a wide variety of clients and works extensively on financial statement audits, reviews, and agreed-upon procedures engagements, in addition to providing consulting services. His industry work spans affordable housing, low-income housing tax credits, housing and urban development, opportunity zones, renewable energy tax credits, market-rate real estate, nonprofits, and private equity.

SESSION 1 – Qualified Rural Opportunity Funds: The 30% Basis Step-Up, Rural Definitions, and Structuring Rural OZ Deals | 12:00pm – 1:00pm

The OBBBA’s biggest new incentive isn’t the permanence — it’s the rural tilt. Qualified rural opportunity funds receive triple the standard basis step-up, and rural property qualifies under a substantial improvement threshold cut in half. This session gives practitioners a working command of the QROF rules, the statutory “rural area” definition, and how rural OZ deals pencil differently from urban ones.

BREAK | 1:00pm – 1:10pm

SESSION 2 – The 2027 OZ Map and the New Reporting Regime: Tract Designations, Sections 6039K/6039L, and Fund-Level Compliance | 1:10pm – 2:10pm

A smaller, stricter OZ map takes effect January 1, 2027, and with it a statutory reporting regime with real penalties. This session covers the new tract designation criteria and disclosure timeline, the two-year overlap window for existing zones, the disclosures QOFs and QOZBs must now make under Sections 6039K and 6039L, and the audit and cost certification mechanics funds should build now.