Over the past several years, Opportunity Zones have been a frequent topic of discussion among investors, developers, business owners, and community leaders seeking to encourage growth in historically underserved areas. Last year, we previously published a more detailed discussion of the Opportunity Zone program and the significant changes enacted through the One Big Beautiful Bill Act (“OBBBA”). This article is intended as a practical update, providing a brief refresher on the program, an overview of how Opportunity Zones have been utilized in North Carolina, more specifically the Triad, and a look at what stakeholders should be watching as the next generation of Opportunity Zones approaches.
A Brief Refresher
Opportunity Zones were originally created as part of the Tax Cuts and Jobs Act of 2017 to encourage long-term private investment in economically distressed communities. Under the program, certain census tracts were designated as Qualified Opportunity Zones, allowing investors who met various requirements to potentially qualify for favorable federal tax treatment.
Broadly speaking, the program was designed around three principal incentives: (1) the ability to defer certain capital gains that are reinvested into qualifying Opportunity Zone investments, (2) potential tax advantages tied to maintaining a qualifying investment for a specified period of time, and (3) the possibility of excluding appreciation generated by the Opportunity Zone investment itself if applicable holding period requirements are satisfied. These incentives were intended to encourage patient, long-term investment rather than short-term speculation.
In July 2025, Congress enacted the OBBBA, which made the Opportunity Zone program a permanent feature of the Internal Revenue Code. The OBBBA revised the Opportunity Zone framework, establishing a recurring ten-year designation cycle and significantly revising the standards used to determine which communities qualify for designation.
For a more detailed analysis of the program’s tax mechanics, fund structures, and legislative changes, we encourage you to review our earlier presentation on Opportunity Zones and the OBBBA.
How Opportunity Zones Have Been Utilized in North Carolina
North Carolina was originally designated 252 Opportunity Zones distributed across all 100 counties. Those zones include urban centers, smaller municipalities, and rural communities throughout the state, including substantial concentrations in several of the state’s largest counties.
Across North Carolina, Opportunity Zones have generally been associated with a wide variety of projects, including multifamily housing developments, mixed-use redevelopment projects, industrial facilities, adaptive reuse initiatives, and business expansion efforts. Opportunity Zone designations have also been incorporated into broader economic development strategies designed to attract private investment into areas that have historically experienced lower levels of development interest.
Available data suggests that Opportunity Zones have been significantly utilized since the program’s launch. In June 2026, the U.S. Department of the Treasury’s Office of Tax Analysis reported that Qualified Opportunity Funds held approximately $112 billion in Qualified Opportunity Zone property nationwide through the end of the 2024 Tax Year, with roughly 77% of designated Opportunity Zones across the country receiving some level of qualified investment. The Treasury Department also reported the existence of approximately 12,800 Qualified Opportunity Funds and roughly 41,000 taxpayers participating in the program. These figures suggest that Opportunity Zones are not solely a niche tax incentive, but a that the Opportunity Zone program has been widely utilized since its creation.
North Carolina appears to have been an active participant in that trend. According to the Treasury Department’s data, approximately 86% of North Carolina’s Opportunity Zones received some Qualified Opportunity Fund investment through 2024, compared to the 77% national average. The data also indicates that Qualified Opportunity Funds held approximately $3.44 billion in Qualified Opportunity Zone property in North Carolina, placing North Carolina among the top ten states nationally for Opportunity Zone investment activity.
At the same time, measuring the precise impact of Opportunity Zone incentives remains challenging. While investment activity can be tracked and quantified, experts continue to research the statistical significance of the Opportunity Zone Program. It remains difficult to determine whether this investment was spurred by the program or by other economic and development factors.
However, the program has become a familiar component of real estate due diligence, development planning, and investment analysis. Even when a project is not specifically structured around Opportunity Zone incentives, the presence of a designated zone may be relevant to the broader development and investment analysis surrounding a property.
The Opportunity Zone Story in the Triad
The Triad has been one of North Carolina’s most significant Opportunity Zone regions. Guilford County contains twelve designated Opportunity Zones, while Forsyth County contains eleven, giving the core Triad region at least twenty-three designated zones under the original program. As a result, Greensboro, Winston-Salem, High Point, and surrounding communities have been among the North Carolina communities most directly affected by Opportunity Zone designations over the last several years.
Many of the Triad’s Opportunity Zones overlap with long-term redevelopment priorities, including downtown revitalization initiatives, redevelopment of former industrial properties, workforce housing efforts, and strategic business recruitment programs. In many respects, Opportunity Zones have complemented economic development efforts that were already underway throughout the region.
One notable Greensboro example is The Steelhouse, a major redevelopment project located within a federally designated Opportunity Zone in East Greensboro. The project involves the transformation of the former Carolina Steel manufacturing campus into a hub for entrepreneurship, manufacturing, food production, artisans, and small business development. The approximately 220,000-square-foot facility is intended to provide space and resources for growing businesses while seeking to encourage additional investment and economic activity in the surrounding area.
The Steelhouse illustrates how Opportunity Zones can overlap with broader redevelopment initiatives. The project combines the redevelopment of an existing industrial property with efforts to support manufacturing, entrepreneurship, and small-business development. Rather than serving as a stand-alone development tool, Opportunity Zone designation frequently operates alongside local government support, nonprofit initiatives, economic development programs, and other financing mechanisms.
Of course, it can be difficult to identify the precise impact that Opportunity Zone incentives have had on a particular project. Nonetheless, the program has brought attention to investment opportunities throughout portions of the Triad that might otherwise receive less consideration from investors and developers.
Looking Ahead to 2027
The most significant Opportunity Zone development currently on the horizon is the transition to the next generation of designated zones.
Under the OBBBA, a new round of Opportunity Zone designations will take effect, while the existing 2018 designations generally remain in effect through December 31, 2028. States have been engaged in the nomination process for the next round of Opportunity Zones, which are expected to become effective January 1, 2027. Going forward, Opportunity Zone designations will occur on recurring ten-year cycles rather than remaining fixed indefinitely.
For North Carolina, the redesignation process is substantial. Based on current eligibility data, the state may nominate up to 202 census tracts for designation from a pool of approximately 807 eligible census tracts statewide. That represents a reduction from the current program and reflects the more restrictive eligibility standards established under the OBBBA.
The revised eligibility criteria have also changed the geographic distribution of potentially qualifying areas. Unlike the original 2018 designation process, not every North Carolina county contains an eligible tract. According to the North Carolina Department of Commerce, Camden, Clay, Currituck, Davie, Gates, Perquimans, and Yancey Counties no longer contain a qualifying census tract under the revised standards. As a result, only 93counties currently have at least one tract eligible for nomination. Of those 202 available nominations, each of the 93 eligible counties will be able to nominate at least one tract, with the remaining nomination allocations distributed among counties containing multiple eligible tracts based upon population.
North Carolina has completed its public-input period and is proceeding with the nomination process. As of the date of this article, the final map of 2027 Opportunity Zones has not yet been released. Accordingly, across the state, communities and investors alike are still waiting to learn whether they will retain an Opportunity Zone designation, lose an existing designation, or receive a new designation under the revised program framework.
Conclusion
Nearly a decade after its creation, the Opportunity Zone program has cemented itself as a permanent component of the federal economic development landscape. In North Carolina, and particularly across the Triad, Opportunity Zones have become part of broader conversations regarding redevelopment, business growth, housing, and community investment.
The next chapter of the program is now taking shape. While the current Opportunity Zone framework remains in effect through December 31, 2028, attention is increasingly turning toward the 2027 designation cycle and the communities that will be selected under the new framework.
As North Carolina completes its nominations and the Treasury Department considers and certifies the proposed designations, local governments, property owners, developers, investors, and community organizations will be watching closely to see how the next Opportunity Zone map takes shape. We will continue monitoring developments and plan to provide additional updates once the new designations are finalized and the long-term impact on North Carolina communities become clearer.
About the Author
Gaaron Goldsmith is an associate attorney in Carruthers & Roth’s Commercial Real Estate practice. He assists clients with a broad range of needs related to buying, selling, developing or leasing property. Gaaron received both his B.A. and J.D. from the University of North Carolina at Chapel Hill, where he was a Dean’s fellow, a mentor to first-year law students, and a staff member of the Journal of International Law. Gaaron can be reached at (336) 478-1150 or gug@crlaw.com.