Treasury approves 238 new Opportunity Zones in Georgia, fewer than in 2018
The second round of Opportunity Zones takes effect Jan. 1, and early state counts show smaller maps than the first round, so a tract that qualified in 2018 may not qualify in 2027.
By Raymond de Clairmont · · 3 min read
Treasury opened the second Opportunity Zone designation cycle on July 1, with 25,332 eligible census tracts nationwide, 8,334 of them qualifying for rural benefits [1]. Governors could designate up to 25% of their low-income tracts [2]. Treasury credited the incentive with “tens of billions” of private investment since it was created in 2017 [1].
By Oct. 29, Treasury had approved 238 zones for Georgia, split nearly evenly between rural and metro areas [2], and 44 for Iowa [3].
The new maps are smaller in all three states
We calculate that Georgia has about 8% fewer zones than in 2018 and Iowa about 29% fewer, while Massachusetts nominated about 25% fewer [2][3][4][5][6]. Massachusetts spread its 104 nominations across 46 municipalities and said certification was expected within weeks of its Oct. 2 submission [4].
Georgia said it picked tracts by combining local nominations, a model of where development was likely and existing statewide priorities [2]. Treasury said a state that skipped an eligible tract this cycle has to wait for the next one, about 10 years away [1].
Rural zones carry larger tax benefits
Massachusetts summarized the rules for qualified rural opportunity funds, which invest in zones that meet the rural test [4]. Roughly a third of eligible tracts nationwide qualify, by our math from Treasury’s count of 8,334 rural tracts out of 25,332 [1].
| Rule | Rural fund | Other funds |
|---|---|---|
| Basis step-up after five years | 30% | 10% |
| Substantial improvement threshold | 50% | 100% |
| Designation period | Jan. 1, 2027 to Dec. 31, 2036 | Jan. 1, 2027 to Dec. 31, 2036 |
How to use this
For developers and landowners
- Look up your parcel’s census tract on your state’s new list before you market it as an Opportunity Zone site. Georgia posted an interactive map of its 2027 designations [2].
- Do not rely on a 2018 designation for a 2027 deal. Iowa’s count fell from 62 to 44 [3][6], so some tracts that qualified before are off the map.
- Price rural renovations against the lower test. On a building with a $400,000 basis, we calculate the 50% rural threshold means $200,000 of improvements, against $400,000 at 100% [4].
- In states still waiting on Treasury, ask the state economic development office for its submitted list. Massachusetts published its nominations, 104 tracts across 46 municipalities, before Treasury certified them [4].
For investors with capital gains
- Ask your tax adviser how the step-up applies to your gain and when an investment can start. Treasury said the new tracts are eligible for investment beginning Jan. 1, 2027 [1].
- Compare rural and non-rural funds on the same gain. On a $1 million deferred gain, we calculate a 30% step-up excludes $300,000 and a 10% step-up excludes $100,000 [4].
For fund sponsors
- Re-check every pipeline project against the final state lists, and tell investors in writing which assets sit in a 2027 zone. Georgia’s 238 approved zones compare with 260 in 2018 [2][5].
- Build 2027 offering documents around the Dec. 31, 2036 end of the designation period, since the zones run on a fixed 10-year cycle [1][4].
This is market commentary, not investment or legal advice.
Sources
- [1]U.S. Department of the Treasury, Treasury Opens the New Designation Cycle for Opportunity Zones, Jul 1, 2026.
- [2]Georgia Department of Community Affairs, Georgia Federal Opportunity Zones 2.0 Program, Oct 29, 2026.
- [3]Iowa Economic Development Authority, Opportunity Zones, Oct 30, 2026.
- [4]Commonwealth of Massachusetts, 2026 Massachusetts Opportunity Zone Program, Oct 2, 2026.
- [5]Office of the Governor of Georgia, Deal: Department of Treasury designates Qualified Opportunity Zones in Georgia, Apr 16, 2018.
- [6]Office of U.S. Sen. Joni Ernst, Treasury approves Iowa’s 62 opportunity zones, May 2018.






