If you invested (or planned to invest) in Opportunity Zones a few years ago, you probably remember the 2026 deadline hanging over everyone’s head. Good news: in July 2025, Congress overhauled the program—locking in long-term certainty and tweaking how the benefits work from 2027 onward. For South Fulton, that means OZs remain a viable—and in some cases compelling—tool for retail, mixed-use, small hotel/extended-stay, and neighborhood infill plays.
Quick refresher: what OZs do (in plain English)
- Defer tax on eligible capital gains by reinvesting into a Qualified Opportunity Fund (QOF). Under the legacy rules, deferral runs until the earlier of a sale or December 31, 2026. Hold 10+ years and post-investment gains can be tax-free.
- South Fulton has multiple designated OZ census tracts, including areas along and near Fulton Industrial Boulevard and key southside corridors. The Georgia DCA and Fulton County GIS portals list the official tracts.
What changed in 2025—and why it matters
- Program permanence & a new clock (starting 2027): The “One Big Beautiful Bill” made OZs permanent, but changes how initial gain deferral works after 12/31/2026. Instead of a single 2026 cutoff, investors get a rolling five-year deferral window from the date of investment, plus a 10% basis step-up after five years (the old extra 5% at seven years goes away). The 10-year tax-free exit on OZ gains remains. Most new provisions take effect in 2027.
- Tighter targeting & oversight: Expect stricter tract eligibility and reporting, with special enhancements for rural QOZs (for example, reduced “substantial improvement” threshold to 50% in qualifying rural areas—note: this rural change doesn’t apply to South Fulton).
So…what if I invest before the end of 2026?
You’re still under the legacy framework: deferral of eligible gains until sale or Dec 31, 2026, and the potential for a tax-free exit on appreciation after a 10-year hold. If your deal pencils now, you don’t need to wait for 2027 to benefit.
Where South Fulton fits right now
South Fulton’s OZ tracts sit near distribution corridors, industrial employment, and emerging neighborhood retail nodes—useful ingredients for small-format grocers, wellness/medical services, QSR pads, neighborhood retail, and select-service/extended-stay hotel where labor, ADR, and operating simplicity matter. (Use DCA’s tract list and the county GIS map to verify your site is actually in a QOZ before modeling.)
Plays I’m advising in 2025–2026
- Small-box retail with real tenant demand. Demise or ground-up in the 1,200–2,500 SF sweet spot, with shells that flex for food-service or wellness. Keep sitework simple; prioritize parking ratios and drive-thru stacking where allowed.
- Extended-stay or limited-service hotel (new build or conversion). Focus on durable demand drivers (industrial, airport-adjacent, logistics, film production). Keep PIPs tight and guest-visible.
- Mixed-use on corners with traffic & rooftops. Retail first; residential units above if zoning and capital stack support it.
- Value-add in existing OZ retail centers. Target curb appeal, lighting, signage, utility upgrades, and TI that shortens lease-up.
Underwriting tips for today’s capital and rates
- Debt & coverage: Underwrite to conservative DSCR with today’s coupons; let the OZ benefit enhance after-tax returns, not rescue a weak pro forma.
- Incentives you can actually monetize: Rate buydowns and builder-style concessions are showing up across asset classes—capture them where possible on build and lease-up to offset carrying costs. (This dynamic has helped new construction compete in 2025.)
- Construction scope discipline: OZ or not, lenders are rewarding simpler, lower-change-order projects. Keep contingencies real.
- Exit clarity: For pre-2027 investments, model both (a) 2026 inclusion of deferred gains under the old rules and (b) a 10-year hold for the tax-free appreciation benefit.
Compliance: don’t wing it
- Confirm the tract. Pull the tract number from Georgia DCA’s list and map. Georgia Department of Community Affairs
- Structure correctly. Use (or create) a Qualified Opportunity Fund and ensure substantial improvement or original use tests are met. IRS
- Mind timelines. 180-day reinvestment windows and working capital safe harbors still matter. Keep counsel and tax advisors looped in.
Is it still worth it?
For cash-flow-credible South Fulton deals—where tenant demand is visible and scope is disciplined—yes, OZ status can still be meaningful in October 2025. It won’t turn a marginal site prime, but it can improve after-tax IRR, especially when paired with pragmatic leasing, lighter capex, and realistic debt. With permanence on deck in 2027 (and a new rolling deferral), OZs are evolving from “deadline scramble” to a repeatable tool—and South Fulton’s tract mix continues to offer approachable deal sizes for local and regional capital.
Next step: If you have a site along or near Fulton Industrial, Old National, or the emerging neighborhood nodes and you want a yes/no read on OZ eligibility and feasibility, I’ll run a quick screen (tract check, rent comps, likely tenant set) and outline the capital stack options in plain English.
Want the checklist? Reply “Tenant Toolkit” and I’ll send my OZ pre-flight (tract verification, QOF structure notes, timelines, and a lender conversation script).
OR, Click Here to schedule a quick 15 minute consultation.
Sources & tools: IRS OZ FAQ; IRS 2025 guidance; Georgia DCA OZ tract list; Fulton County GIS; Kiplinger & Barron’s summaries of the 2025 law; Novogradac mapping