Congress created the Qualified Opportunity Zone program (“QOZ 1.0”) through the Tax Cuts and Jobs Act of 2017 1 to encourage long-term investment in economically distressed communities. By offering tax incentives, the program sought to channel private capital into designated urban, suburban, and rural areas, where new development, business formation, and job creation could help drive economic revitalization. Nearly a decade later, the program is entering a new phase.