Much has been written about the new Opportunity Zone (OZ) rules that convey substantial tax breaks for development in targeted low-income areas, with most of the attention focused on traditional brick and mortar real estate businesses. There’s been little discussion about the potential benefits for oil and gas exploration and development.

Of the roughly 15 states that contain 90% or more of domestic onshore development and production, many have extremely productive formations in rural OZs. This begs the question: Can oil and gas assets and development activities constitute qualified OZ properties and business activities? It is believed the answer is yes. 

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