“is amended by inserting "(50 percent of such adjusted basis in the case of property in a qualified opportunity zone comprised entirely of a rural area (as defined in subsection (b)(2)(C)(ii))" after "the adjusted basis of such property".”
The section inserts words into section 1400Z-2(d)(2)(D)(ii) of the Internal Revenue Code of 1986 setting the substantial improvement test at 50 percent of adjusted basis for property in a zone made up entirely of a rural area. It also replaces the fixed December 31, 2017 acquisition dates in the property, stock and partnership interest tests with the applicable start date and a new applicable date term.
What the document actually says
“is amended by inserting "(50 percent of such adjusted basis in the case of property in a qualified opportunity zone comprised entirely of a rural area (as defined in subsection (b)(2)(C)(ii))" after "the adjusted basis of such property".”
That sentence, in plain words
New words are put into a rule on improving property. They set the test at 50 percent of the value on the books. That holds in a zone that is all rural.
What this is about
Elsewhere the test is higher. A lower test is easier to meet. Fixed dates in nearby rules are also replaced.
No action is recorded against this proposal. That is not evidence that none has been taken, and nobody has yet read it against the record. See what the tracker does not yet cover.
Provide for reconciliation pursuant to title II of H. Con. Res. 14, Public Law 119-21, sec. 70421, 139 Stat. 223 (2025). https://www.govinfo.gov/content/pkg/PLAW-119publ21/html/PLAW-119publ21.htm
This page
“The improvement threshold in a rural zone is cut to 50 percent,” Provide for reconciliation pursuant to title II of H. Con. Res. 14, section 70421, Sec. 70421. Read the Mandate, https://readthemandate.org/pl-119-21/proposal/sec70421-rural-improvement/ (retrieved October 10, 2026).
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