cent of the census blocks which comprise such 
county are rural blocks (as determined by the 
Bureau of the Census as of the date of the en-
actment of this Act). A rule similar to section 
143(k)(2)(D) shall apply for purposes of the 
preceding sentence. 
‘‘(e) APPLICABLE RULES.— 
‘‘(1) TREATMENT
OF
INVESTMENTS
WITH 
MIXED FUNDS.—In the case of any investment in a 
qualified rural opportunity fund only a portion of 
which consists of investments of gain to which an 
election under subsection (a) is in effect— 
‘‘(A) such investment shall be treated as 2 
separate investments, consisting of— 
‘‘(i) one investment that only includes 
amounts to which the election under sub-
section (a) applies, and 
‘‘(ii) a separate investment consisting 
of other amounts, and 
‘‘(B) subsections (a), (b), and (c) shall 
only apply to the investment described in sub-
paragraph (A)(i). 
‘‘(2) RELATED PERSONS.—For purposes of this 
section, persons are related to each other if such 
persons are described in section 267(b) or 707(b)(1), 
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determined by substituting ‘20 percent’ for ‘50 per-
cent’ each place it occurs in such sections. 
‘‘(3) DECEDENTS.—In the case of a decedent, 
amounts recognized under this section shall, if not 
properly includible in the gross income of the dece-
dent, be includible in gross income as provided by 
section 691. 
‘‘(4) REGULATIONS.—The Secretary shall pre-
scribe such regulations as may be necessary or ap-
propriate to carry out the purposes of this section, 
including— 
‘‘(A) rules for the certification of qualified 
rural opportunity funds for the purposes of this 
section, 
‘‘(B) rules to ensure a qualified rural op-
portunity fund has a reasonable period of time 
to reinvest the return of capital from invest-
ments in qualified rural opportunity zone stock 
and qualified rural opportunity zone partner-
ship interests, and to reinvest proceeds received 
from the sale or disposition of qualified rural 
opportunity zone property, and 
‘‘(C) rules to prevent abuse. 
‘‘(f) FAILURE OF QUALIFIED RURAL OPPORTUNITY 
FUND TO MAINTAIN INVESTMENT STANDARD.— 
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‘‘(1) IN GENERAL.—If a qualified rural oppor-
tunity fund fails to meet the 90-percent requirement 
of subsection (d)(1), the qualified rural opportunity 
fund shall pay a penalty for each month it fails to 
meet the requirement in an amount equal to the 
product of— 
‘‘(A) the excess of— 
‘‘(i) the amount equal to 90 percent of 
its aggregate assets, over 
‘‘(ii) the aggregate amount of quali-
fied rural opportunity zone property held 
by the fund, multiplied by 
‘‘(B) the underpayment rate established 
under section 6621(a)(2) for such month. 
‘‘(2) SPECIAL RULE FOR PARTNERSHIPS.—In 
the case that the qualified rural opportunity fund is 
a partnership, the penalty imposed by paragraph (1) 
shall be taken into account proportionately as part 
of the distributive share of each partner of the part-
nership. 
‘‘(3) REASONABLE
CAUSE
EXCEPTION.—No 
penalty shall be imposed under this subsection with 
respect to any failure if it is shown that such failure 
is due to reasonable cause.’’. 
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(b) CLERICAL AMENDMENT.—The table of sections 
for subchapter Z of chapter 1 is amended by adding at 
the end the following new item: 
‘‘Sec. 1400Z–3. Special rules for capital gains invested in rural opportunity 
zones.’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall apply to amounts invested after the date 
of the enactment of this section. 
SEC. 7. REPORTING ON QUALIFIED OPPORTUNITY FUNDS 
AND 
QUALIFIED 
RURAL 
OPPORTUNITY 
FUNDS. 
(a) IN GENERAL.— 
(1) FILING
REQUIREMENTS
FOR
FUNDS
AND 
INVESTORS.—Subpart A of part III of subchapter A 
of chapter 61 is amended by inserting after section 
6039J the following new sections: 
‘‘SEC. 6039K. RETURNS WITH RESPECT TO QUALIFIED OP-
PORTUNITY FUNDS AND QUALIFIED RURAL 
OPPORTUNITY FUNDS. 
‘‘(a) IN GENERAL.—Every qualified opportunity fund 
shall file an annual return (at such time and in such man-
ner as the Secretary may prescribe) containing the infor-
mation described in subsection (b). 
‘‘(b) INFORMATION FROM QUALIFIED OPPORTUNITY 
FUNDS.—The information described in this subsection 
is— 
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‘‘(1) the name, address, and taxpayer identifica-
tion number of the qualified opportunity fund, 
‘‘(2) whether the qualified opportunity fund is 
organized as a corporation or a partnership, 
‘‘(3) the value of the total assets held by the 
qualified opportunity fund as of each date described 
in section 1400Z–2(d)(1), 
‘‘(4) the value of all qualified opportunity zone 
property held by the qualified opportunity fund on 
each such date, 
‘‘(5) with respect to each investment held by 
the qualified opportunity fund in qualified oppor-
tunity zone stock or a qualified opportunity zone 
partnership interest— 
‘‘(A) the name, address, and taxpayer 
identification number of the corporation in 
which such stock is held or the partnership in 
which such interest is held, as the case may be, 
‘‘(B) each North American Industry Clas-
sification System (NAICS) code that applies to 
the trades or businesses conducted by such cor-
poration or partnership, 
‘‘(C) the population census tracts in which 
the qualified opportunity zone business property 
of such corporation or partnership is located, 
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‘‘(D) the amount of the investment in such 
stock or partnership interest as of each date de-
scribed in section 1400Z–2(d)(1), 
‘‘(E) the value of tangible property held by 
such corporation or partnership on each such 
date which is owned by such corporation or 
partnership, 
‘‘(F) the value of tangible property held by 
such corporation or partnership on each such 
date which is leased by such corporation or 
partnership, 
‘‘(G) the approximate number of residen-
tial units (if any) for any real property held by 
such corporation or partnership, and 
‘‘(H) the approximate average monthly 
number of full-time equivalent employees of 
such corporation or partnership for the year 
(within numerical ranges identified by the Sec-
retary) or such other indication of the employ-
ment impact of such corporation or partnership 
as determined appropriate by the Secretary, 
‘‘(6) with respect to the items of qualified op-
portunity zone business property held by the quali-
fied opportunity fund— 
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1 shall have the meaning given such term under 
such subchapter. 
‘‘(2) FULL-TIME
EQUIVALENT
EMPLOYEES.— 
The term ‘full-time equivalent employees’ means, 
with respect to any month, the sum of— 
‘‘(A) the number of full-time employees (as 
defined in section 4980H(c)(4)) for the month, 
plus 
‘‘(B) the number of employees determined 
(under rules similar to the rules of section 
4980H(c)(2)(E)) by dividing the aggregate 
number of hours of service of employees who 
are not full-time employees for the month by 
120. 
‘‘(e) APPLICATION TO QUALIFIED RURAL OPPOR-
TUNITY FUNDS.—Every qualified rural opportunity fund 
shall file the annual return required under subsection (a), 
and the statements required under subsection (c), ap-
plied— 
‘‘(1) by substituting ‘qualified rural oppor-
tunity’ for ‘qualified opportunity’ each place it ap-
pears, and 
‘‘(2) by substituting ‘section 1400Z–3(d)(1)’ for 
‘section 1400Z–2(d)(1)’ each place it appears. 
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‘‘SEC. 6039L. INFORMATION REQUIRED FROM QUALIFIED 
OPPORTUNITY 
ZONE 
BUSINESSES 
AND 
QUALIFIED 
RURAL 
OPPORTUNITY 
ZONE 
BUSINESSES. 
‘‘(a) IN GENERAL.—Every applicable qualified oppor-
tunity zone business shall furnish to the qualified oppor-
tunity fund described in subsection (b) a written state-
ment in such manner and setting forth such information 
as the Secretary may by regulations prescribe for purposes 
of enabling such qualified opportunity fund to meet the 
requirements of section 6039K(b)(5). 
‘‘(b) APPLICABLE QUALIFIED OPPORTUNITY ZONE 
BUSINESS.—For purposes of subsection (a), the term ‘ap-
plicable qualified opportunity zone business’ means any 
qualified opportunity zone business— 
‘‘(1) which is a trade or business of a qualified 
opportunity fund, 
‘‘(2) in which a qualified opportunity fund holds 
qualified opportunity zone stock, or 
‘‘(3) in which a qualified opportunity fund holds 
a qualified opportunity zone partnership interest. 
‘‘(c) OTHER TERMS.—Any term used in this section 
which is also used in subchapter Z of chapter 1 shall have 
the meaning given such term under such subchapter. 
‘‘(d) APPLICATION TO QUALIFIED RURAL OPPOR-
TUNITY FUNDS.—Every qualified rural opportunity zone 
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business (as defined in subsection (b) determined after ap-
plication of the substitutions described in this sentence) 
shall furnish the written statement required under sub-
section (a), applied by substituting ‘qualified rural oppor-
tunity’ for ‘qualified opportunity’ each place it appears.’’. 
(2) PENALTIES.— 
(A) IN GENERAL.—Part II of subchapter 
B of chapter 68 is amended by inserting after 
section 6725 the following new section: 
‘‘SEC. 6726. FAILURE TO COMPLY WITH INFORMATION RE-
PORTING 
REQUIREMENTS 
RELATING 
TO 
QUALIFIED 
OPPORTUNITY 
FUNDS 
AND 
QUALIFIED RURAL OPPORTUNITY FUNDS. 
‘‘(a) IN GENERAL.—In the case of any person re-
quired to file a return under section 6039K fails to file 
a complete and correct return under such section in the 
time and in the manner prescribed therefor, such person 
shall pay a penalty of $500 for each day during which 
such failure continues. 
‘‘(b) LIMITATION.— 
‘‘(1) IN
GENERAL.—The maximum penalty 
under this section on failures with respect to any 1 
return shall not exceed $10,000. 
‘‘(2) 
LARGE
QUALIFIED
OPPORTUNITY 
FUNDS.—In the case of any failure described in sub-
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section (a) with respect to a fund the gross assets 
of which (determined on the last day of the taxable 
year) are in excess of $10,000,000, paragraph (1) 
shall be applied by substituting ‘$50,000’ for 
‘$10,000’. 
‘‘(c) PENALTY
IN CASES
OF INTENTIONAL DIS-
REGARD.—If a failure described in subsection (a) is due 
to intentional disregard, then— 
‘‘(1) subsection (a) shall be applied by sub-
stituting ‘$2,500’ for ‘$500’, 
‘‘(2) subsection (b)(1) shall be applied by sub-
stituting ‘$50,000’ for ‘$10,000’, and 
‘‘(3) subsection (b)(2) shall be applied by sub-
stituting ‘$250,000’ for ‘$50,000’. 
‘‘(d) INFLATION ADJUSTMENT.— 
‘‘(1) IN GENERAL.—In the case of any failure 
relating to a return required to be filed in a calendar 
year beginning after 2023, each of the dollar 
amounts in subsections (a), (b), and (c) shall be in-
creased by an amount equal to such dollar amount 
multiplied by the cost-of-living adjustment deter-
mined under section 1(f)(3) for the calendar year 
determined by substituting ‘calendar year 2022’ for 
‘calendar year 2016’ in subparagraph (A)(ii) thereof. 
‘‘(2) ROUNDING.— 
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‘‘(A) IN
GENERAL.—If the $500 dollar 
amount in subsection (a) and (c)(1) or the 
$2,500 amount in subsection (c)(1), after being 
increased under paragraph (1), is not a mul-
tiple of $10, such dollar amount shall be round-
ed to the next lowest multiple of $10. 
‘‘(B) 
ASSET
THRESHOLD.—If 
the 
$10,000,000 dollar amount in subsection (b)(2), 
after being increased under paragraph (1), is 
not a multiple of $10,000, such dollar amount 
shall be rounded to the next lowest multiple of 
$10,000. 
‘‘(C) OTHER
DOLLAR
AMOUNTS.—If any 
dollar amount in subsection (b) or (c) (other 
than any amount to which subparagraph (A) or 
(B) applies), after being increased under para-
graph (1), is not a multiple of $1,000, such dol-
lar amount shall be rounded to the next lowest 
multiple of $1,000.’’. 
(B) INFORMATION REQUIRED TO BE SENT 
TO OTHER TAXPAYERS.—Section 6724(d)(2) is 
amended— 
(i) by striking ‘‘or’’ at the end of sub-
paragraph (II), 
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(ii) by striking the period at the end 
of the first subparagraph (JJ) (relating to 
section 6226) and inserting a comma, 
(iii) by redesignating the second sub-
paragraph (JJ) (relating to section 6050Y) 
as subparagraph (KK), 
(iv) by striking the period at the end 
of subparagraph (KK) (as redesignated by 
clause (iii)) and inserting a comma, and 
(v) by inserting after subparagraph 
(KK) (as so redesignated) the following 
new subparagraphs: 
‘‘(LL) section 6039K(c) (relating to dis-
position of qualified opportunity fund invest-
ments), or 
‘‘(MM) section 6039L (relating to informa-
tion required from certain qualified opportunity 
zone businesses and qualified rural opportunity 
zone businesses).’’. 
(3) ELECTRONIC FILING.—Section 6011(e) is 
amended by adding at the end the following new 
paragraph: 
‘‘(8) QUALIFIED
OPPORTUNITY
FUNDS
AND 
QUALIFIED RURAL OPPORTUNITY FUNDS.—Notwith-
standing paragraphs (1) and (2), any return filed by 
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a qualified opportunity fund or qualified rural oppor-
tunity fund shall be filed on magnetic media or other 
machine-readable form.’’. 
(4) CLERICAL AMENDMENTS.— 
(A) The table of sections for subpart A of 
part III of subchapter A of chapter 61 is 
amended by inserting after the item relating to 
section 6039J the following new items: 
‘‘Sec. 6039K. Returns with respect to qualified opportunity funds and qualified 
rural opportunity funds. 
‘‘Sec. 6039L. Information required from certain qualified opportunity zone 
businesses and qualified rural opportunity zone businesses.’’. 
(B) The table of sections for part II of 
subchapter B of chapter 68 is amended by in-
serting after the item relating to section 6725 
the following new item: 
‘‘Sec. 6726. Failure to comply with information reporting requirements relating 
to qualified opportunity funds and qualified rural opportunity 
zone businesses.’’. 
(5) EFFECTIVE DATE.—The amendments made 
by this subsection shall apply to taxable years begin-
ning after the date of the enactment of this Act. 
(b) REPORTING OF DATA ON OPPORTUNITY ZONE 
AND RURAL OPPORTUNITY ZONE TAX INCENTIVES.— 
(1) IN GENERAL.—As soon as practical after 
the date of the enactment of this Act, and annually 
thereafter, the Secretary of the Treasury, or the 
Secretary’s delegate (referred to in this section as 
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the ‘‘Secretary’’), in consultation with the Director 
of the Bureau of the Census and such other agencies 
as the Secretary determines appropriate, shall make 
publicly available a report on qualified opportunity 
funds. 
(2) INFORMATION INCLUDED.—The report re-
quired under paragraph (1) shall include, to the ex-
tent available, the following information: 
(A) The number of qualified opportunity 
funds. 
(B) The aggregate dollar amount of assets 
held in qualified opportunity funds. 
(C) The aggregate dollar amount of invest-
ments made by qualified opportunity funds in 
qualified opportunity fund property, stated sep-
arately for each North American Industry Clas-
sification System (NAICS) code. 
(D) The percentage of population census 
tracts designated as qualified opportunity zones 
that have received qualified opportunity fund 
investments. 
(E) For each population census tract des-
ignated as a qualified opportunity zone, the ap-
proximate average monthly number of full-time 
equivalent employees of the qualified oppor-
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tunity zone businesses in such qualified oppor-
tunity zone for the preceding 12-month period 
(within numerical ranges identified by the Sec-
retary) or such other indication of the employ-
ment impact of such qualified opportunity fund 
businesses as determined appropriate by the 
Secretary. 
(F) The percentage of the total amount of 
investments made by qualified opportunity 
funds in— 
(i) qualified opportunity zone property 
which is real property; and 
(ii) other qualified opportunity zone 
property. 
(G) For each population census tract, the 
aggregate approximate number of residential 
units resulting from investments made by quali-
fied opportunity funds in real property. 
(H) The aggregate dollar amount of in-
vestments made by qualified opportunity funds 
in each population census tract. 
(3) ADDITIONAL INFORMATION.— 
(A) IN GENERAL.—Beginning with the re-
port submitted under paragraph (1) for the 6th 
year after the date of the enactment of this Act, 
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the Secretary shall include in such report the 
impacts and outcomes of a designation of a 
population census tract as a qualified oppor-
tunity zone as measured by economic indicators, 
such as job creation, poverty reduction, new 
business starts, and other metrics as deter-
mined by the Secretary. 
(B) SEMI-DECENNIAL INFORMATION.— 
(i) IN GENERAL.—In the case of any 
report submitted under paragraph (1) in 
the 6th year or the 11th year after the 
date of the enactment of this Act, the Sec-
retary shall include the following informa-
tion: 
(I) For population census tracts 
designated as a qualified opportunity 
zone, a comparison (based on aggre-
gate information) of the factors listed 
in clause (iii) between the 5-year pe-
riod ending on the date of the enact-
ment of Public Law 115–97 and the 
most recent 5-year period for which 
data is available. 
(II) For population census tracts 
designated as a qualified opportunity 
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zone, a comparison (based on aggre-
gate information) of the factors listed 
in clause (iii) for the most recent 5- 
year period for which data is available 
between such population census tracts 
and a similar population census tracts 
that were not designated as a quali-
fied opportunity zone. 
(ii) CONTROL GROUPS.—For purposes 
of clause (i), the Secretary may combine 
population census tracts into such groups 
as the Secretary determines appropriate 
for purposes of making comparisons. 
(iii) FACTORS
LISTED.—The factors 
listed in this paragraph are the following: 
(I) The unemployment rate. 
(II) The number of persons 
working in the population census 
tract, including the percentage of such 
persons who were not residents in the 
population census tract in the pre-
ceding year. 
(III) 
Individual, 
family, 
and 
household poverty rates. 
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(IV) Median family income of 
residents of the population census 
tract. 
(V) Demographic information on 
residents of the population census 
tract, including age, income, edu-
cation, race, and employment. 
(VI) The average percentage of 
income of residents of the population 
census tract spent on rent annually. 
(VII) The number of residences 
in the population census tract. 
(VIII) The rate of home owner-
ship in the population census tract. 
(IX) The average value of resi-
dential property in the population cen-
sus tract. 
(X) The number of affordable 
housing units in the population census 
tract. 
(XI) The number and percentage 
of residents in the population census 
tract that were not employed for the 
preceding year. 
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(XII) The number of new busi-
ness starts in the population census 
tract. 
(XIII) The distribution of em-
ployees in the population census tract 
by North American Industry Classi-
fication System (NAICS) code. 
(4) PROTECTION OF IDENTIFIABLE RETURN IN-
FORMATION.—In making reports required under this 
subsection, the Secretary— 
(A) shall establish appropriate procedures 
to ensure that any amounts reported do not dis-
close taxpayer return information that can be 
associated with any particular taxpayer or com-
petitive or proprietary information, and 
(B) if necessary to protect taxpayer return 
information, may combine information required 
with respect to individual population census 
tracts into larger geographic areas. 
(5) DEFINITIONS.—Any term used in this para-
graph which is also used in subchapter Z of chapter 
1 of the Internal Revenue Code of 1986 shall have 
the meaning given such term under such subchapter. 
(6) REPORTS
ON
QUALIFIED
RURAL
OPPOR-
TUNITY FUNDS.—The Secretary shall make publicly 
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available, with respect to qualified rural opportunity 
funds, separate reports as required under this sub-
section, applied— 
(A) by substituting ‘‘qualified rural oppor-
tunity’’ for ‘‘qualified opportunity’’ each place it 
appears, and 
(B) by substituting ‘‘the Small Business 
Jobs Act’’ for ‘‘Public Law 115–97’’. 
Æ 
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