Farm CPA Report

Farm CPA Report

Guidance on Rural Opportunity Zones

OBBBA made changes to the Opportunity Zones and there are new benefits for rural areas

Paul Neiffer's avatar
Paul Neiffer
Oct 09, 2025
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The One Big Beautiful Bill Act made certain changes to Opportunity Zones and added in what is called Rural Opportunity Zones. The benefit of a rural opportunity zone is that instead requiring 100% of the funds be used for improvements, now the threshold is only 50%. This makes it much easier for rural opportunity zones to meet the rules.

But what is a rural opportunity zone. The IRS just released Notice 2025-50 to provide guidance on this definition.

In the notice, the IRS defined a rural opportunity zone as any zone that is not too close to a community with a population greater than 50,000. The notice then listed 3,309 opportunity zones from the previous 2010 census that would qualify as a rural opportunity zone.

The notice does not provide any guidance on what new opportunity zones will be listed as rural zones since there will be an update based on the 2020 census.

Farmers are allowed to set up their own opportunity zone “fund”. The benefit of an opportunity zone is that a farmer can:

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