The Tax Cuts and Jobs Act added the Opportunity Zones concept as Section 1400Z to the Internal Revenue Code, which is designed to incentivize private investment in low income areas. That section of the Code allows the governors of each state to designate certain low income census tracts as an Opportunity Zone (OZ) and the governor of every state has done so. To participate, investors must create an Opportunity Fund (OF) to invest in new projects in an OZ, typically with moneys obtained from the recent sale of existing assets.