Opportunity Zones 101 with Expert Barrett Linburg

In this episode of the Major League Real Estate Podcast, Nathan Sosa sits down with Barrett Linburg, Managing Partner at Savoy Equity Partners, to break down how Qualified Opportunity Zones (QOZs) and Qualified Opportunity Funds (QOFs) work in practice, what investors need to know about structuring deals, and the impact these investments can have on communities.

Barrett’s Background and First OZ Deal

Barrett started in real estate in 2012 with an 8-unit rehab and grew into buying, renovating, and managing dozens of properties. In 2020, while pursuing a deal, he discovered the project was in an Opportunity Zone. With support from forward-thinking attorneys and CPAs, he launched his first OZ portfolio, a move that has since led to over $100 million of OZ equity under management.

Why Opportunity Zones Are Different

Unlike traditional real estate tax strategies, OZs are relatively new. That means there’s little case law or IRS guidance, and practitioners are often writing the playbook in real time. Barrett emphasized the importance of:

• Aligning with both the spirit and letter of the law
• Leaning on experienced CPAs and attorneys
• Structuring deals carefully to withstand potential IRS scrutiny

QOFs and QOZBs Explained

Opportunity Zone investing requires a two-tier structure:

• The QOF (where investor money is pooled)
• The QOZB (where the real estate is held)

Barrett explained why paperwork matters, from filing Forms 8996 and 8997 correctly to providing detailed K-1s that make it easier for CPAs to handle client returns. While investors can set up their own QOFs, Barrett cautioned that it usually only makes sense for gains of $1M+.

Evaluating the Right Zones

With over 8,500 eligible census tracts, site selection is critical. Barrett looks for areas “in the path of progress” by considering:

• Demographic shifts and income maps
• Proximity to high-income neighborhoods
• The ability to make a meaningful local impact through multiple projects

Savoy Equity Partners has concentrated heavily in Dallas, building over 20 projects within a one-mile radius to help drive long-term transformation.

Key Lessons and Investor Considerations

Barrett shared several important takeaways:

• Business fundamentals come first — the OZ tax benefits are the “cherry on top.”
• Liquidity isn’t gone for 10 years — refinance proceeds and rental income can provide cash flow before the final exit.
• Keep structures simple — plain vanilla real estate deals with conservative leverage often outperform complex financing schemes.

OZ 2.0: What’s New

The updated Opportunity Zone rules bring major changes:

• Permanency — OZs are now a permanent part of the tax code, with new maps every 10 years.
• Five-year rolling deferral — replacing the expiring 2026 deadline.
• Rural incentives — larger discounts on deferred tax bills and reduced improvement requirements.

Final Thoughts

Opportunity Zones remain one of the most powerful tools in real estate investing, offering unique tax benefits while channeling capital into communities that need it most. As Barrett highlighted, success comes from pairing strong business fundamentals with careful structuring and a long-term mindset.

Our team at Hall CPA specializes in helping investors navigate Opportunity Zones, 1031 exchanges, and proactive tax planning strategies that keep more of your money working for you.

Book a free discovery call with our team.

Disclaimer: This podcast summary was generated from the transcript and may contain some errors or miss key points from the audio recording. Any mention of third-party vendors, products, or services does not constitute an endorsement or recommendation. You should conduct your own due diligence before engaging with any vendor.