The Internal Revenue Service (IRS) released a second set of regulations concerning the Opportunity Zone program on April 17, 2019. These regulations address a plethora of previously unresolved issues that potential investors have sought clarity on since enactment. Most notably, the regulations clarify the 10-year exit rules, contain rules about leased property, provide safe harbors for the 50% gross income test, and clarify original use and substantial improvement requirements, among other rules. In general, these regulations are generous to taxpayers. However, the limited relief for interim gains, disqualification of carried interest, and remaining uncertainty about unaddressed provisions are a disappointment to potential investors. In this article, published in the Tax Management Real Estate Journal by Bloomberg Tax, Tax Strategy & Benefits partner Steve Mount analyzes the new regulations and the impact they will have on opportunity funds.