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

The OBBBA rewrote opportunity zones: qualified rural opportunity funds earn a 30% basis step-up, a smaller map arrives January 1, 2027, and Sections 6039K and 6039L impose penalty-backed reporting. Learn to structure QROF deals, map qualifying rural tracts, and build fund-level compliance.

2026-09-14 12:00:00

Program Details

2026-09-14 12:00:00

Program Details

2026-09-14 12:00:00

Over 1,000+ webinars

2026-09-14 12:00:00

Course Overview

The Biggest New OZ Incentive Isn't Permanence — It's the Rural Tilt

2026-09-14 12:00:00

The OBBBA’s rural tilt is the headline change. Qualified rural opportunity funds receive a 30% basis step-up at year five, triple the standard 10%. Rural property qualifies under a substantial improvement threshold cut in half — and that rule is already effective. A smaller, stricter OZ map follows on January 1, 2027, carrying a statutory reporting regime with real penalties.

The deadlines are already set. OZ 1.0 tract benefits run only through December 31, 2028. Existing zones get a two-year overlap window; misread it and a client misses 2.0 benefits. QOFs and QOZBs must disclose housing unit and employment data under Sections 6039K and 6039L, with penalty exposure for noncompliance. Clients in de-designated tracts need advice now, not in 2027.

Attendees leave with a working command of the QROF rules and the statutory “rural area” definition, models for when the 30% step-up changes the investment decision, fund formation and LPA drafting issues, and the audit, cost certification, and semiannual asset testing mechanics funds should build now.

Format

CLE Credit

2h CLE Credits

Level

Intermediate

Length

2

Key topics that will be covered

01
QROF Economics
How the 30% basis step-up at year five, the 100%-rural asset composition requirement, and the already-effective 50% substantial improvement threshold change rural acquisition/rehab underwriting and when the step-up flips the investment decision.
02
Mapping Rural Tracts
Applying the statutory “rural area” definition — the 50,000-population test and adjacent urbanized areas — to determine which tracts qualify for rural OZ treatment.
03
Structuring Rural Deals
Property acquisition thresholds, depreciable basis planning, fund formation and LPA drafting issues, exit and liquidity strategies, and layering rural OZ equity with NMTCs, historic tax credits, and renewable energy credits.
04
The 2027 Map
Tightened designation criteria, elimination of contiguous-tract urban designations, the governor nomination process, post-June 30, 2026 tract disclosures, the ten-year redesignation cycle, and advising clients in de-designated tracts.
05
Overlap Window Planning
OZ 1.0 tract benefits running through December 31, 2028, when a 1.0 tract investment can capture 2.0 benefits, transition planning and QROF qualification risks, and open questions for Treasury guidance.
06
Reporting and Audit Readiness
Sections 6039K and 6039L disclosures and penalty exposure, Treasury’s annual public reports, rural QOZB compliance, financial statement audits, cost certification, and semiannual asset testing under the new regime.

Program schedule

clock 12:00 pm - 1:00 pm EST

Qualified Rural Opportunity Funds: The 30% Basis Step-Up, Rural Definitions, and Structuring Rural OZ Deals

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.

Marc L. SchultzMarc L. Schultz
Brent ParkerBrent Parker
clock 1:10 pm - 2:10 pm EST

The 2027 OZ Map and the New Reporting Regime: Tract Designations, Sections 6039K/6039L, and Fund-Level Compliance

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.

Marc L. SchultzMarc L. Schultz
Brent ParkerBrent Parker
Marc L. Schultz

Marc L. Schultz

Snell & Wilmer

Brent Parker

Brent Parker

Novogradac & Company LLP

Marc L. Schultz

Marc L. Schultz

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

Brent Parker

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.
Marc L. Schultz

Marc L. Schultz

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

Brent Parker

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.

Credits by state

AK2.0
AL2.0
AR2.0
AZ2.0
CA2.0
CO2.0
CT2.0
DC2.0
DE2.0
FL2.0
GA2.0
HI2.0
IA2.0
ID2.0
IL2.0
IN2.0
KS2.0
KY2.0
LA2.0
MA2.0
MD2.0
ME2.0
MI2.0
MN2.0
MO2.4
MS2.0
MT2.0
NC2.0
ND2.0
NE2.0
NH120.0
NJ2.0
NM2.0
NV2.0
NY2.0
OH2.0
OK2.5
OR2.0
PA2.0
RI2.5
SC2.0
SD2.0
TN2.0
TX2.0
UT2.0
VA2.0
VT2.0
WA2.0
WI2.0
WV2.4
WY2.0

1000+

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24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Approved
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Approved
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Approved
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Approved
Texas
Approved
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Approved
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

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  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs