Tangible property is qualified opportunity zone business property if: it is tangible property used in the QOF's or QOZB's trade or business; it is either acquired by purchase from an unrelated party after Dec. 31, 2017, or leased after Dec. 31, 2017 (there are special rules for leases from related parties); if the original use of purchased property in the QOZ does not originate with the QOF or QOZB, the property must be substantially improved (more than its tax basis (at the beginning of a 30-month period) must be spent improving the property. The code says that a substantial improvement must be done during any 30-month period that the QOF or QOZB owns the property (which would mean that the amount that must be spent is tested at the beginning of the 30 month period selected by the QOF or QOZB). But there is some indication that the IRS and Treasury believe that the 30-month period starts on the acquisition date (which means that the amount that must be spent is more than the cost of the property). Lastly, during 90% of the QOF's or QOZB's holding period for the property, at least 70% of the use is in the QOZ. The QOZ tax rules are very intricate and complicated. You should consult with your tax advisors.