Could the property and management safe harbor extend to a software company that has coders and salespeople outside of the Opportunity Zone? What if the employees never come to the zone?
It's conceivable, but you'd need to justify to the IRS why this was done for legitimate reasons and not to game the system. If it's two officers in the "headquarters" and 100 remote employees, that's a stretch. If it's five total people in "headquarters" and five remote workers, that looks better.
There are several ways to satisfy the OZ rules.
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