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Reconvene '26 will host an off-the-record "Opportunity Zones 2.0" breakout in…

2026-07-15 · 14:45 UTC ·@DallasAptGP ·2 min read

Brief

Moses Kagan is promoting an Opportunity Zones 2.0 breakout at Reconvene '26 (Oct 6–8, Santa Monica) aimed at investors with large capital gains (he explicitly calls out gains from SpaceX or AI stock) and real‑estate operators seeking capital. The session, led by Barrett Linburg (Savoy, >$250M OZ portfolio) and Jimmy Atkinson (OpportunityZones.com; author), promises plain‑English, tactical guidance: prioritize underwriting the real estate before relying on OZ tax benefits; explain OZ advantages (tax escape vs. 1031, no income caps, zero depreciation recapture and tax‑free appreciation after 10 years); decode the OZ 2.0 map process (tract nominations now, certification in Q4, live 1/1/2027); and give concrete deployment timing (e.g., 2025 K‑1s needing mid‑September deployment vs. deferring some gains into 2027 for a 5‑year step‑up). The session will also cover fee compression from national funds and strategies to preserve returns by investing direct or via family/captive vehicles, plus real projects straddling the 1.0→2.0 transition.

Why it matters

Reconvene '26 will host an off-the-record "Opportunity Zones 2.0" breakout in Santa Monica (Oct 6–8, 2026) led by Barrett Linburg (co‑founder of Savoy; Savoy OZ portfolio > $250M) and Jimmy Atkinson (founder of OpportunityZones.com; author of The Opportunity Zones Playbook).

Key details

  • Primary tactical rule: "Underwrite the Deal First, the Tax Last" — Opportunity Zones are framed as a tax layer, not an investment strategy, and offer 'tax escape' (vs. 1031 deferment), no income caps (unlike a Roth), and zero depreciation recapture plus tax‑free appreciation after a 10‑year hold.
  • OZ 2.0 timing and maps: tracts are being nominated now, certifications expected in Q4, and new boundaries go live on January 1, 2027; the session will map which gains must be deployed into 2026 funds (examples cited: 2025 K‑1s needing deployment by mid‑September and first‑half 2026 personal gains) versus gains you can delay into 2027 to capture new 5‑year deferral/step‑up benefits.
  • Fee and structuring risk: national OZ funds can stack secondary promotes and annual fees that compound over a 10‑year hold and depress returns; recommended alternatives include direct operator investments and captive family funds, and operators who can run compliant funds will be preferred by capital.
Source evidence

I enjoy educating people about real estate investing and the power of the Opportunity Zone tax structure

Look forward to doing so in Santa Monica at the ReConvene Conference in October with Jimmy Atkinson who literally just wrote the book on OZ

Hope some of you will join

Moses Kagan (@moseskagan)

Are you an investor who has recently or will shortly realize a large capital gain (maybe from SpaceX or AI stock)?

Are you a real estate operator seeking capital for heavy value-add or development projects?

If your answer to either or both of these questions is "yes", then you should strongly consider attending the Opportunity Zones 2.0 Breakout at Reconvene '26.

We have brought in two experts to lead this off-the-record discussion:

  • Barrett Linburg: Co-founder of Savoy, a vertically integrated multifamily platform in Texas with an OZ portfolio exceeding $250 million, an active advocate for OZ legislation in Washington, and long-time friend of Reconvene.

  • Jimmy Atkinson: Founder and CEO of OpportunityZones​.com and the host of The Opportunity Zones Podcast. He is the author of The Opportunity Zones Playbook and has been a leading authority on OZ investing since 2018.

This is a plain-English, tactical strategy session designed for both high-net-worth investors looking to deploy capital and the developers and GPs who want to partner with them.

Here is a look at what we will cover in the room:

  • Underwrite the Deal First, the Tax Last: OZ is a tax layer, not an investment strategy. We will discuss how to evaluate the underlying real estate to ensure you are buying an asset you would want to own anyway.

  • The Power of the Layer: We will explore why OZ is one of the cleanest tax strategies available. It offers tax escape (rather than deferment, like a 1031 exchange), has no income caps (unlike a Roth), and provides zero depreciation recapture on top of your tax-free appreciation after a 10-year hold.*

  • The Maps are Being Drawn Now: OZ 2.0 brings a new map. Tracts are being nominated right now, will be certified in Q4, and go live January 1, 2027. We will show you how to read the new boundaries.

  • What to Do with a Gain Right Now: We will discuss how to handle the 1.0 to 2.0 transition in practice. We will map out exactly which gains must go into a 2026 fund (such as 2025 K-1s needing deployment by mid-September or first-half 2026 personal gains) and which can be delayed into 2027 to capture the new 5-year deferral and step-up benefits.

  • Navigating the Fee Layer: National OZ funds often stack a secondary promote and annual fees on top of the developer’s economics, which compounds and reduces returns over a 10-year hold. We will outline ways to cut out the middleman, including direct operator investing and captive family funds.

  • The Developer's Perspective: As investors learn to go direct to save on fees, the operators who can run a compliant fund and deliver the real estate become the preferred destination for this capital.

  • Real-World Case Studies: A look at live projects currently straddling the OZ 1.0 to 2.0 transition timeline.

For more information about Reconvene '26 (10/6-10/8 in Santa Monica, CA) or to buy tickets, please visit reconvene.com

— https://nitter.net/moseskagan/status/2077376383815458931#m