Original use still requires that the taxpayer be the first one to use it in the zone. The regulations have rules regarding the vacant property; generally, if the property was vacant on Dec. 31, 2017 all the way through to a 2020 purchase date, the taxpayer achieves original use. The more nuanced provision in the regulations regarding Brownfield remediation is that any of those costs count toward substantial improvement, so to the extent, there are existing structures on the property, that could make a significant difference.
