7818 / When is “substantially all” of a business’ property used in a qualified opportunity zone?

Under the second set of regulations governing opportunity zones, the IRS has clarified that substantially all of the property owned or leased by a business is used in an opportunity zone if at least 70 percent of the business’ tangible property was used in a qualified opportunity zone. It should be noted, however, that this standard is different than the “substantially all” standard used to determine whether the holding period requirement is satisfied, where a 90 percent requirement applies.