New IRS Guidance Clarifies Rules for Rural Opportunity Zones

On October 13, 2025, the IRS and U.S. Treasury released Notice 2025-50, offering significant clarification on provisions of the Opportunity and Betterment for Business Bill (OBBB) related specifically to rural Qualified Opportunity Zones (QOZs). This update addresses long-standing questions and introduces changes that make rural investments more accessible and attractive to investors. 

What Are Qualified Opportunity Zones?

Qualified Opportunity Zones (QOZs) are designated economically distressed communities identified in 2018 under the Tax Cuts and Jobs Act. They were created to encourage long-term private investment in low-income areas through a range of federal tax incentives. 

Two Major Updates from IRS Notice 2025-50

The new guidance focuses on: 

  1. Clarifying the Definition of a “Rural Area” 
  2. Revising the Substantial Improvement Threshold for Rural Properties 

1. What Counts as a “Rural Area”?

The IRS now defines a “rural area” as: 

  • Any area not located within a city or town with a population exceeding 50,000. 
  • Any area not adjacent to or part of an urbanized area surrounding such cities or towns. 
  • This definition applies uniformly across all U.S. states, the District of Columbia, and U.S. territories. 

This clearer definition enables more consistent identification of rural QOZs and expands eligibility for new investment opportunities. 

2. Lower Investment Threshold for Rural QOZs

A major hurdle for investors in QOZs has been the substantial improvement test, which previously required that investors improve a property by 100% of its original basis, excluding land, in order to qualify for QOZ tax benefits. 

Under the new guidance: 

  • For properties located entirely within rural QOZs, the substantial improvement threshold has been reduced to 50%. 
  • This change took effect on July 4, 2025. 
  • It applies to all tangible property located in a rural QOZ that is being, or has been, substantially improved on or after that date. 

This reduction is expected to lower the barrier to entry for rural development projects, thereby encouraging more investment in these underserved areas. 

Scope and Impact

  • There are currently 8,764 designated QOZs across the United States. 
  • Of these, 3,309 zones now qualify as entirely rural under the new definition. 
  • The updated rules are designed to promote economic revitalization in rural communities, many of which have historically experienced lower levels of private investment. 

What’s Next?

The Treasury Department and IRS have announced plans to issue further guidance on: 

  • The next round of QOZ nominations. 
  • Designation procedures for newly authorized zones under the OBBB. 
  • For a full list of current QOZs, refer to IRS Notice 2018-48. 

How Sai CPA Can Help

Understanding and leveraging Qualified Opportunity Zones—especially with these new rural provisions—can be complex but highly rewarding. At Sai CPA, we help investors, developers, and business owners: 

  • Evaluate eligibility for rural QOZ investments 
  • Navigate the reduced improvement thresholds 
  • Maximize available tax benefits 
  • Stay compliant with ongoing IRS updates 

Have questions about how these changes affect your investment strategy? 
Contact Sai CPA today for expert guidance. 

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