Notice 2018-48 and Notice 2019-42

list census tracts that were nominated in 2018, which the Secretary certified and designated as QOZs (2018 QOZs). The 2018 QOZs were based on census tracts and boundaries based on the 2010 Decennial Census. No census tract has been designated as a QOZ since the designations of the 2018 QOZs.

Under § 1400Z-2(d)(1), the term “qualified opportunity fund” (QOF) means any investment vehicle organized as a corporation or a partnership for the purpose of investing in “qualified opportunity zone property” (QOZP) that holds at least 90 percent of its assets in QOZP. Pursuant to § 1400Z-2(d)(2) (A)(iii), QOZP includes, among other things, “qualified opportunity zone business property” (QOZBP).

1 Unless otherwise specified, all “section” or “§” references are to sections of the Code.

October 20, 2025 542 Bulletin No. 2025–43

While the definition of rural area in § 1400Z-2(b)(2)(C)(ii), as enacted by the OBBBA, is the same as that of the Con Act and 7 U.S.C. 1991(a)(13)(A), the OBBBA definition does not include the additional statutory provisions for defining a rural area that are found in 7 U.S.C. 1991(a)(13)(D) through (I). Hence, the methodology this notice applies for determining a rural area for purposes of § 1400Z-2(b)(2)(C)(ii) is broadly similar to the methodology used by the USDA for its rural development programs, but does not correspond in all respects to the additional details provided in 7 U.S.C. 1991(a)(13).