Opportunity Zone data centers
Put a large capital gain to work in data centers.
Gains invested in a Qualified Opportunity Fund from January 1, 2027 can defer federal tax for up to five years, exclude 10% of the deferred gain (30% in a rural fund) and grow free of federal tax after ten years.2 We sponsor Opportunity Zone data center projects, manage the funds that invest in them and run the businesses that own them.
For accredited investors and their advisers. Confidential, and a person replies within two business days.
Where to start
Tell us which describes you.
I have a capital gain
From selling a business, stock, real estate, crypto or a fund interest. See your deadline, then how investing with us works.
Check your 180-day deadline →How it works for gain holdersI advise or allocate capital
Family offices, wealth managers, RIAs and CPAs placing gains for clients. We walk through structure, reporting and diligence in a call.
Start an allocator conversation →Due diligence checklistI'm developing a data center or own land
A site in or near an Opportunity Zone with a path to power. We tell you whether it can hold a data center and be structured as an OZ deal.
Submit a site or project →Is my land in an Opportunity Zone?The 180-day clock
When did you sell? Your deadline starts there.
You generally have 180 days from the day a gain is realized to invest it in a Qualified Opportunity Fund.2 Enter the date and, if you like, the amount. Nothing is sent to us until you choose to send it.
- Partnership and S corporation gains (K-1) can start the clock later.
- Installment sales can start a new window with each payment.
- Section 1231 gains start on the date of the sale.
Enter a date to see your deadline. You generally have 180 days from the day a gain is realized to invest it in a Qualified Opportunity Fund, counting the sale date as day 1.
Illustrative only. Uses a 23.8% federal rate (20% plus 3.8% net investment income tax), assumes the investment is held at least five years and does not fall in value, and ignores state tax. Not tax advice, and not an offer of any security. Confirm dates and amounts with your tax adviser.
For capital gain holders
Built for gains measured in millions.
If you have sold, or are about to sell, a business, a block of stock, real estate or another appreciated asset, a Qualified Opportunity Fund lets that gain keep working while the tax waits. We put it into data centers: long-lived, capital-intensive projects that match the program's ten-year hold.
One accountable sponsor
We originate the project, manage the fund and run the operating business. Site selection is by BlackForge Data Centers.
A plan built around your deadline
We start from your 180-day window and plan the investment around it, alongside the fund's asset test and the project's build schedule.
Rural and urban projects
Projects can be sited in rural zones, where a Qualified Rural Opportunity Fund earns a 30% step-up at five years instead of 10%.
Reporting for the long hold
Investor reporting built around the five-year and ten-year marks, and around the annual information returns funds and their businesses file.
How it works, from first call to funding
Step 1
Inquiry
Tell us the size, source and timing of your gain. Confidential, and you are not committing to anything.
Step 2
Introductory call
We confirm your timing and how the gain arose, ask whether you are an accredited investor and explain how our projects and funds are structured.
Step 3
Your advisers join
We work alongside your CPA, attorney or wealth manager on timing and the deferral election. We do not give personal tax advice.
Step 4
Offering documents
If there is a fit and you qualify, you receive the fund's confidential offering documents to review with your advisers.
Step 5
Subscription and funding
You decide whether to invest. If you do, you subscribe and fund within your 180-day window, and your adviser makes the deferral election with your tax return.
Usually a fit
- Business owners selling a company or a stake in one
- Investors with large gains from stock, funds or a concentrated position
- Owners selling real estate, farmland or other property
- Families and trusts with gains from crypto or other digital assets
- Partners and S corporation shareholders with gains reported on a K-1
Our fund offerings are generally limited to accredited investors, as defined by the SEC. If you are not sure whether you qualify, ask us or your adviser. We will tell you plainly.
Who can invest in an Opportunity Zone fund →Advising a client with a gain?
CPAs, attorneys, wealth managers and family offices are welcome to contact us first, with or without the client named. We will walk you through structure, timing and reporting so you can judge the fit.
Start an adviser conversation →Opportunity Zones for CPAs and advisersOpportunity Zones for family officesWhy invest in an Opportunity Zone
Three tax benefits, on one clock.
These benefits apply to capital gains invested in a Qualified Opportunity Fund on or after January 1, 2027.5
- to invest a capital gain in a Qualified Opportunity Fund2
- 180 days
- of the deferred gain excluded after five years (30% in rural funds)2
- 10% / 30%
- held, and the investment's growth can be free of federal tax2
- 10 years
- census tracts eligible for the zones that take effect January 1, 20274
- 25,332
Tax on the gain waits up to five years
You owe nothing on the invested gain until you sell the fund investment or five years pass, whichever comes first.2
10% of the gain is excluded from tax
At five years your basis steps up by 10% of the deferred gain. Through a Qualified Rural Opportunity Fund, it is 30%.2
Growth after ten years is tax-free
Hold at least ten years and elect to step the basis up to fair market value when you sell, so the appreciation escapes federal tax.2
The Opportunity Zone clock
- Day 0Sell an asset at a gainStock, a business, real estate or other capital gain property.
- Day 180Invest the gain in a QOFOnly the gain needs to be invested, not the full sale price.
- Year 5Deferred gain comes dueTaxed on 90% of it, or 70% through a rural fund.
- Year 10Growth becomes tax-freeElect fair market value basis when you sell.
- Year 30Exclusion stops growingBasis is fixed at the 30-year value.
The math
What a $1 million gain can become.
The same gain, the same investment return, three paths. The difference comes from deferring the tax, excluding part of the gain and paying no federal tax on ten years of growth.
See the full worked example →- Pay the tax now, invest the rest$1.34M$238,000 tax today; $762,000 doubles; 23.8% tax on the growth
- Invest the gain in a QOF$1.79MTax on $900,000 paid in year 5; growth tax-free at year 10
- Invest through a rural QOF (QROF)$1.83MTax on $700,000 paid in year 5; growth tax-free at year 10
Our approach
One team at every layer of the deal.
Most Opportunity Zone deals pass between a sponsor, a fund manager, an operator and a site consultant who have never worked together. We bring all four under one roof, so OZ deadlines and data center timelines stay in step.
- 1 · Sponsor
We originate the deal
Each project starts with us: the site thesis, the capital plan, the build partners and the timeline that keeps it inside the Opportunity Zone rules.
OZ Data Centers
- 2 · Fund
We manage the fund
Investors put eligible capital gains into a Qualified Opportunity Fund that we manage, with reporting built around the OZ holding periods.
OZ Data Centers
- 3 · Operating business
We run the QOZB
The data center is owned by a Qualified Opportunity Zone Business. It is managed day to day for compliance, construction and performance.
With QOZB Management LLC
- 4 · Site
We pick land that can take a data center
Before a dollar is committed, every site is screened for power, water, fiber, terrain and zoning, and sized for the data center it can actually support.
With BlackForge Data Centers
Who stands behind the projects
QOZB Management LLC
Management and compliance for Qualified Opportunity Zone Businesses.
BlackForge Data Centers
Data center site selection and land screening: 17.1 million parcels screened across the United States, including nearly 500,000 acres in a single engagement.
BlackForge Ventures
The parent company. OZ Data Centers is a BlackForge Ventures company.
- sponsor, fund, operating business and site work under one roof
- 4 layers
- parcels screened by BlackForge Data Centers
- 17.1M
- acres screened in a single landowner engagement
- ~500K
- sourced guides on Opportunity Zone law and data centers
- 90
Why data centers
Data centers and Opportunity Zones are built for each other.
The program pays investors to commit large amounts of capital to new property in the zone and to hold it for at least ten years. Few asset classes match that as closely as a data center: long-lived, usually built from the ground up, extraordinarily capital-intensive and increasingly sited where land and transmission are available, often in rural areas.
The fit is not automatic. Leasing structures, short-lived IT equipment and long power timelines all need to be planned around the rules. That is the work we do.
Data centers in Opportunity Zones: the complete guideHave a site? Submit it →For developers and landowners
Have a site or a project? We bring the capital and the structure.
We look for data center projects and land in or near Opportunity Zones. BlackForge Data Centers screens every site for power, water, fiber, terrain and zoning before capital is committed, and we structure the project to meet the Opportunity Zone rules.
Developers
Projects from early site search to shovel-ready, at any scale. We can come in as sponsor, as an equity partner or as both, and the fund and operating business sit with us.
Submit your project →Opportunity Zones for data center developersLandowners
Large parcels with transmission nearby are the starting point. We tell you whether the land can hold a data center and whether it sits in, or near, a zone.
Submit your site →Opportunity Zones for landownersBlackForge Data Centers has screened 17.1 million parcels across the United States, including nearly 500,000 acres in a single engagement for one landowner.
Represent a county, utility or economic development group? Talk to us →What is an Opportunity Zone
A low-income census tract where long-term investment earns a tax break.
An Opportunity Zone is a census tract that meets a low-income test, is nominated by its state's governor and is certified by the Treasury.3 Investors who put capital gains into a Qualified Opportunity Fund that invests in those tracts get three federal tax benefits: deferral, a partial exclusion and, after ten years, tax-free growth.2
The program is permanent.1 Governors nominate a new set of zones every ten years. The current nomination round opened July 1, 2026, and the zones it produces take effect January 1, 2027 and last through December 31, 2036.4
- Step 1Low-income census tractMeets the statute's income or poverty test.
- Step 2Governor nominatesEach state picks from its eligible tracts.
- Step 3Treasury certifiesNominated tracts become designated zones.
- Step 4Zone for 10 yearsNew maps every ten years, permanently.
Which tracts can become Opportunity Zones
| Rule | What the law says |
|---|---|
| Income test | Median family income at or below 70% of the area median, or a poverty rate of at least 20% with median family income at or below 125% of the area median.3 |
| How many | Each governor may designate up to 25% of the state's eligible tracts (or 25 tracts, if greater).9 |
| How long | Ten years. Zones designated in the current round run January 1, 2027 through December 31, 2036.4 |
| Rural | A tract outside any city or town of more than 50,000 people and its adjacent urbanized area. Of the 25,332 eligible tracts, 8,334 are wholly rural.4,6 |
How Opportunity Zones work
Gain, fund, business, property.
The money moves through four layers, and each layer has a test it must pass. Most data center projects use the fund-and-business structure below because it gives the project room to build.
- YouInvestor with a capital gainAn individual, trust, partnership or corporation.Invest within 180 days
- FundQualified Opportunity FundA partnership or corporation that self-certifies on Form 8996.90% in zone assets
- BusinessQualified Opportunity Zone BusinessThe operating company that owns and runs the project.70% tangible property in zone
- AssetZone propertyNew construction or substantially improved property in the zone.Original use or improvement
Funds and businesses must meet a 90% asset test, a 70% tangible property test, a 31-month deployment window and a 30-month improvement rule.7 The rules, explained →
New for funds and businesses: annual information returns with daily penalties for missing them. The details are still in proposed regulations.8 Read the reporting guide.
Rural Opportunity Zones
Rural zones get the biggest breaks.
A Qualified Rural Opportunity Fund holds at least 90% of its assets in zones made up entirely of rural areas. Its investors exclude 30% of the deferred gain at five years instead of 10%, and rural property only has to be improved by 50% of its basis instead of 100%.6
- basis step-up at five years
- 30%
- substantial improvement threshold
- 50%
- wholly rural eligible tracts
- 8,334
Key dates
- July 1, 2026Nomination round opensGovernors have 90 days to nominate tracts from Treasury's eligible list.4
- Fall 2026Treasury certifies the new zonesCertification of state nominations is underway as of October 2026.4
- January 1, 2027New zones and new benefits take effectRolling five-year deferral and 10% or 30% step-ups apply to gains invested from this date.4
- December 31, 2036These zones endA new nomination round sets the next ten-year map.4
Questions
Opportunity Zones, answered.
What happens after I send an inquiry?
A member of our team reads it and replies, usually within two business days. If there is a fit, we set up a confidential call to understand your gain and timing and to explain how our projects and funds are structured. Nothing is binding, and any investment is made only through the fund's offering documents.
My gain was in 2026. Which rules apply?
It depends on when you invest, not when you sold. An investment made on or before December 31, 2026 falls under the earlier rules. A 2026 gain invested on or after January 1, 2027, still within its 180-day window, gets the current treatment: deferral for up to five years and a 10% or 30% step-up at five years.
What is an Opportunity Zone?
An Opportunity Zone is a low-income census tract that a governor nominates and the Treasury certifies. Investors who put capital gains into a Qualified Opportunity Fund that invests in these zones can defer tax on those gains, reduce it, and pay no federal tax on the fund investment's growth after ten years.
Are Opportunity Zones permanent?
Yes. Public Law 119-21, signed July 4, 2025, made the program a permanent part of the tax code. Governors nominate new zones every ten years; the next set of zones takes effect January 1, 2027 and runs through December 31, 2036.
How long do I have to invest a capital gain?
Generally 180 days from the date the gain is realized. Partners, S corporation shareholders and taxpayers with section 1231 gains have additional timing options under the regulations.
What is the tax benefit for gains invested after 2026?
For gains invested in a Qualified Opportunity Fund after December 31, 2026, tax on the gain is deferred until the earlier of a sale of the investment or five years after the investment. At five years, 10% of the deferred gain is excluded (30% for a Qualified Rural Opportunity Fund). Hold at least ten years and the investment's appreciation can be excluded from federal tax.
What is a Qualified Rural Opportunity Fund?
A Qualified Opportunity Fund that holds at least 90% of its assets in property located in zones made up entirely of rural areas. It earns a 30% basis step-up at five years instead of 10%, and rural property only has to be improved by 50% of its basis to qualify, instead of 100%.
Why do data centers fit Opportunity Zones?
The program rewards long holds, new construction and large capital investment in the zone, with extra benefits in rural areas. Data centers are long-lived, usually built new, extremely capital-intensive and often sited in rural areas with land and transmission.
Do I have to be an accredited investor?
The tax law does not require it, but most private Opportunity Zone funds are offered under securities exemptions that limit investors to accredited investors. Each fund's offering documents set its eligibility rules.
Do I have to invest the whole sale price?
No. Only the gain needs to be invested to defer it. Your original basis can be kept or used elsewhere.
My 180 days have passed. Is it too late?
Not always. Gains from a partnership or S corporation, installment sales and some business property gains can have later windows. Tell us the details and we will look at it with your adviser.
Is anything about the new rules still pending?
Yes. As of October 2026, Treasury is still certifying the zones that take effect January 1, 2027, and the new fund and business reporting rules exist only as proposed regulations. Our guides flag each pending item.
The Opportunity Zone library
90 guides, every answer sourced.
Plain-English explanations of the rules, the tax math, the zone maps and how data centers fit.
Start with the guide for your situation:Selling a businessSelling real estateFor family offices
Contact
Start a confidential conversation.
Tell us about your gain, your clients' capital or your site. A member of our team reads every inquiry and replies personally, usually within two business days.
What happens next
- 1.A member of our team reads your inquiry personally.
- 2.We reply within two business days, by your preferred method.
- 3.If there is a fit, we set up a confidential call on structure and timing. You can bring your adviser.
Prefer email? info@ozdatacenters.com
For accredited investors and their advisers. Nothing here is an offer of securities.
Sources
- 1.Congress.gov, “H.R. 1, One Big Beautiful Bill Act (Public Law 119-21), text,” 2025. congress.gov
- 2.GovInfo, “26 U.S.C. 1400Z-2, Special rules for capital gains invested in opportunity zones,” 2026. govinfo.gov
- 3.Office of the Law Revision Counsel, “26 U.S.C. 1400Z-1, Designation,” 2026. uscode.house.gov
- 4.Internal Revenue Service, “Treasury, IRS provide guidance to States for nominating census tracts as qualified opportunity zones,” 2026. irs.gov
- 5.Internal Revenue Service, “Notice 2026-40, Transitional guidance on qualified opportunity zones,” 2026. irs.gov
- 6.Internal Revenue Service, “Treasury, IRS provide guidance for Opportunity Zone investments in rural areas (Notice 2025-50),” 2025. irs.gov
- 7.Internal Revenue Service, “Opportunity zones,” n.d.. irs.gov
- 8.Federal Register, “Information reporting regarding qualified opportunity zones (proposed regulations),” 2026. govinfo.gov
- 9.Economic Innovation Group, “Opportunity Zones: where things stand after the One Big Beautiful Bill Act,” 2025. eig.org
- 10.Novogradac, “OBBBA makes OZ incentive permanent, with some significant changes,” 2025. novoco.com