Family offices are increasingly interested in qualified opportunity zones, but most intend to hold off on deploying capital until the programme resets in 2027. New incentives introduced under the One Big Beautiful Bill Act have revived attention, yet advisers say the most compelling benefits will only materialise once the next tranche of zones is designated.
Marcus Baram reports that the sector has slowed in recent years as the original tax advantages approached their 2026 expiry. The OBBBA changes revive the appeal by making the programme permanent, updating deferral rules and expanding designations into rural communities. That shift is already influencing family office strategy, though many investors are choosing to wait in order to maximise tax planning opportunities.
Real estate continues to be a core allocation for family offices, rising from 9 percent in 2023 to 11 percent in 2025 according to Goldman Sachs. Opportunity zones have grown steadily as a vehicle for channeling capital gains into development projects in underserved areas, with investor participation rising from 18 percent of family offices in 2019 to nearly one third in 2024. New incentives in the OBBBA, including longer deferral timelines, increased transparency and improved basis step-ups, are restoring confidence in a programme once seen as overly complex.
Several advisers note a clear uptick in interest. Some family offices stepped back from deals last year due to weak returns even after accounting for tax benefits. With the new rules, however, the pipeline is warming again, especially for families anticipating large capital gains events.
The redesigned programme offers several advantages. Permanence removes the deadline risk. The fixed deferral date has been replaced with a rolling five-year period linked to when gains are realised. The basis step-up has increased from 10 to 15 percent. A quarter of the new zones must be rural, opening new types of investment opportunities and reducing the improvement threshold from 100 percent to 50 percent. Bonus depreciation returns to 100 percent, allowing immediate deduction of qualifying improvements.
Still, advisers agree that the strongest opportunities begin in January 2027 when the newly designated zones come into force. Many refer to the period between now and then as a “dead zone” because the remaining incentives under current rules offer limited advantage. While some investors will still use QOZs in 2026 to house gains or pursue specific real estate deals, most family offices are preparing to wait.
Investing in QOZs requires sector knowledge and experienced partners, given the complexity of development, permitting and local conditions. Joining a qualified opportunity fund remains the norm, providing access to specialist teams and shared risk. Rural expansion is also attracting interest from investors with experience in agriculture and permanent crops, given the enhanced incentives.
For many family offices, the appeal lies in diversification and potential after-tax return enhancement. Stabilising rates and broader volatility make opportunity zones a hedge against traditional asset classes, supported by inflation-linked rental dynamics.
Alongside the investment discussion, Baram highlights a separate but significant trend from UBS’s Billionaires Ambitions Report. The world’s wealthiest families are undergoing a cultural shift: most no longer want their children to inherit or run the family business. Instead, 82 percent want heirs to build independent careers. Only 43 percent hope the next generation continues the existing operating company.
Global billionaire wealth hit $15.8 trillion in 2025, and inheritance activity reached record highs, with 91 heirs receiving nearly $298 billion. This shift away from dynastic business continuity is accelerating professionalisation, M&A activity and next-generation impact investing. Longer life expectancy among wealth holders is also reshaping expectations and prompting new governance and succession pathways. Families increasingly value resilience, adaptability and purpose over inherited titles.
Recent headlines underscore this era of transition: Kenneth Dart’s pivot into gambling stocks, the Benetton family setting up a private-markets platform, and Hermès heir Nicolas Puech’s legal action over alleged unauthorised share sales to LVMH.
