South Carolina has a structural advantage in Opportunity Zones 2.0 that most investors haven’t found yet.
IRS Revenue Procedure 2026-14, issued April 6, 2026, officially confirmed the eligible census tract list for OZ 2.0 designations. When you run the numbers for South Carolina, one fact stands out: 73% of South Carolina’s 445 eligible OZ 2.0 tracts are classified as Rural — 326 tracts qualifying for a 30% basis step-up versus the standard 10%. The national average is 33% rural. South Carolina is running at more than twice that rate.
What rural designation means in practice:
– 30% basis step-up on deferred capital gains (vs. 10% standard)
– 50% substantial improvement threshold (vs. 100% standard)
– Materially better after-tax return profile per dollar invested
The contiguous tract exception has been eliminated under OZ 2.0. Every tract must now independently meet the 70% median family income threshold — which tightened the eligible pool by 17% in South Carolina and 28% nationally. With governors having just 90 days (July 1 – September 28, 2026) to nominate, and the map locking for a full decade on January 1, 2027, the analysis window is short.
We have reviewed every eligible South Carolina census tract against the official IRS Rev. Proc. 2026-14 Appendix — rural status confirmed, county by county, tract by tract, including Florence County, Spartanburg County, Orangeburg County, York County, and all 45 SC counties.
Curious about why SC rural OZ designations and related additional benefits are over 40% higher than standard OZ tracts? Contact us at tara@sherbertgroup.com.

