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.

Jason Watkins, CPA, Partner | Novogradac & Company LLP

Jason Watkins is a partner at Novogradac & Company LLP, based in the firm’s metro Atlanta office. His practice concentrates on the opportunity zones (OZ) incentive along with federal and state new markets tax credits (NMTCs), historic tax credits, and renewable energy tax credits, and he regularly advises qualified opportunity funds, developers, and investors on structuring investments to capture available tax credits and other incentives.

• Education & Credentials

Mr. Watkins earned a bachelor’s degree in business administration from Kent State University and is a Certified Public Accountant licensed in Georgia.

• Recognition & Leadership

Jason plays an active role in Novogradac’s Opportunity Zones initiatives. He leads the firm’s Opportunity Zones Basics workshops, providing educational guidance on the fundamentals of the Opportunity Zones incentive. He also holds a leadership role with the Novogradac-hosted Opportunity Zones Working Group, contributing to the firm’s work and educational efforts in this area.

• Professional Involvement

Jason is a regular contributor to Novogradac’s educational programming and publications. He has served as a speaker at the company’s New Markets Tax Credit preconference workshops and regularly contributes articles concerning Opportunity Zones to the Novogradac Journal of Tax Credits. Through these activities, he provides practical information concerning Opportunity Zones, tax-credit programs, and related compliance considerations.

• Experience

Jason has been with Novogradac since 2012, where his experience has included financial statement audits, tax return preparation, cost certification audits, and Opportunity Zone and New Markets Tax Credit compliance reporting and consulting services. His work has given him experience across both accounting and tax-credit-related services.

His current practice concentrates on Opportunity Zones and a range of federal and state tax-credit programs, including NMTCs, historic tax credits, and renewable energy tax credits. He regularly advises qualified opportunity funds, developers, and investors regarding investment structures and the requirements associated with capturing and maintaining available tax incentives. His combination of accounting experience, CPA credentials, and specialized work with tax-credit programs supports his advisory role on transactions involving these incentive programs.

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.