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Treasury, IRS provide guidance for Opportunity Zone investments in rural areas under the One, Big, Beautiful Bill

September 30, 2025

from the IRS

WASHINGTON — The Department of the Treasury and the Internal Revenue Service today issued guidance on Qualified Opportunity Zone investments in rural areas as provided for under the One, Big, Beautiful Bill.

In 2018, certain economically distressed census tracts in the United States and its territories were designated as Qualified Opportunity Zones by the Treasury Department. Taxpayers who invest in QOZs receive certain tax benefits for their investments as an incentive to improve economic growth and job creation in these underserved communities.  

What’s new under the OBBB

Notice 2025-50 provides clarification on two important One, Big, Beautiful Bill provisions: the definition of “rural area” and the application of the substantial improvement threshold for certain improvements to property located in a QOZ that is comprised entirely of a rural area.

  • Under the new law, a rural area means any area other than a city or town with a population greater than 50,000, and any urbanized area contiguous and adjacent to a city or town with a population greater than 50,000. This definition applies to States, the District of Columbia and U.S. territories.
  • The OBBB modified the substantial improvement threshold for improvements to property located in a QOZ that is comprised entirely of a rural area. As of July 4, 2025, the substantial improvement threshold for required additions to the basis for property located in these QOZs was reduced from 100 percent to 50 percent.

These changes are intended to offer enhanced QOZ tax incentives for investing in underserved rural areas and to address the unique challenges of rural development. There are currently 8,764 QOZs in the United States, many of which have experienced a lack of investment for decades. The notice released today by the Treasury Department and the IRS identifies 3,309 of those QOZs as comprised entirely of a rural area. A list of all current, designated QOZs is found in Notice 2018-48.

More information

Notice 2025-50 applies to all tangible property located in a QOZ that is comprised entirely of a rural area on or after July 4, 2025, and that has been, or is in the process of being, substantially improved. The Treasury Department and the IRS intend to issue future guidance on the forthcoming round of opportunity zones authorized by the OBBB, including the nomination and designation procedures.

For more information, refer to the One, Big, Beautiful Bill provisions page on IRS.gov.