‘‘(B) qualified gigabit opportunity zone 
partnership interest, 
‘‘(C) qualified gigabit opportunity zone 
business property, or 
‘‘(D) an interest in a qualified investment 
fund. 
‘‘(2) QUALIFIED GIGABIT OPPORTUNITY ZONE 
STOCK.— 
‘‘(A) IN GENERAL.—Except as provided in 
subparagraph (B), the term ‘qualified gigabit 
opportunity zone stock’ means any stock in a 
domestic corporation if— 
‘‘(i) such stock is acquired by the tax-
payer after the date of the enactment of 
this section, at its original issue (directly 
or through an underwriter) from the cor-
poration solely in exchange for cash, 
‘‘(ii) as of the time such stock was 
issued, such corporation was a qualified 
gigabit opportunity zone business (or, in 
the case of a new corporation, such cor-
poration was being organized for purposes 
of being a qualified gigabit opportunity 
zone business), and 
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‘‘(iii) during substantially all of the 
taxpayer’s holding period for such stock, 
such corporation qualified as a qualified 
gigabit opportunity zone business. 
‘‘(B) REDEMPTIONS.—A rule similar to 
the rule of section 1202(c)(3) shall apply for 
purposes of this paragraph. 
‘‘(3) QUALIFIED GIGABIT OPPORTUNITY ZONE 
PARTNERSHIP INTEREST.—The term ‘qualified gig-
abit opportunity zone partnership interest’ means 
any capital or profits interest in a domestic partner-
ship if— 
‘‘(A) such interest is acquired by the tax-
payer after the date of the enactment of this 
section, from the partnership solely in exchange 
for cash, 
‘‘(B) as of the time such interest was ac-
quired, such partnership was a qualified gigabit 
opportunity zone business (or, in the case of a 
new partnership, such partnership was being 
organized for purposes of being a qualified gig-
abit opportunity zone business), and 
‘‘(C) during substantially all of the tax-
payer’s holding period for such interest, such 
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partnership qualified as a qualified gigabit op-
portunity zone business. 
‘‘(4) QUALIFIED GIGABIT OPPORTUNITY ZONE 
BUSINESS PROPERTY.— 
‘‘(A) IN
GENERAL.—The term ‘qualified 
gigabit opportunity zone business property’ 
means tangible property used in a trade or 
business of the taxpayer if— 
‘‘(i) such property— 
‘‘(I) is used primarily to provide 
broadband transmission services to 
areas which do not have fixed terres-
trial broadband service that meets the 
current speed benchmark for fixed 
services (as determined by the Federal 
Communications Commission in its 
most recent report issued pursuant to 
section 706 of the Telecommuni-
cations Act of 1996 (47 U.S.C. 
1302)), and 
‘‘(II) is capable of transmitting 
signals 
at 
a 
rate 
of 
at 
least 
1,000,000,000 bits per second, 
‘‘(ii) such property was acquired by 
the taxpayer by purchase (as defined in 
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section 179(d)(2)) after the date of the en-
actment of this section, 
‘‘(iii) the original use of such property 
in the qualified gigabit opportunity zone 
commences with the taxpayer or the tax-
payer substantially improves the property, 
and 
‘‘(iv) during substantially all of the 
taxpayer’s holding period for such prop-
erty, substantially all of the use of such 
property was in a qualified gigabit oppor-
tunity zone. 
‘‘(B) SPECIAL RULE FOR CERTAIN PROP-
ERTY.—In the case of property which is placed 
in service before January 1, 2024, and which is 
with respect to technology described in para-
graph (4) or (5) of subsection (c), subpara-
graph (A)(i)(II) shall be applied by substituting 
‘150,000,000 
bits 
per 
second’ 
for 
‘1,000,000,000 bits per second’. 
‘‘(C) SUBSTANTIAL
IMPROVEMENT.—For 
purposes of subparagraph (A)(iii), property 
shall be treated as substantially improved by 
the taxpayer only if, during any 30-month pe-
riod beginning after the date of acquisition of 
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such property, additions to basis with respect to 
such property in the hands of the taxpayer ex-
ceed an amount equal to the adjusted basis of 
such property at the beginning of such 30- 
month period in the hands of the taxpayer. 
‘‘(D) TREATMENT
OF
RELATED
PAR-
TIES.—For purposes of subparagraph (A)(ii), 
the rules of subparagraph (A) of section 
179(d)(2) shall be applied using the relation-
ship described in subsection (e)(2) in lieu of the 
relationship described in such subparagraph. 
‘‘(5) 
QUALIFIED
GIGABIT
OPPORTUNITY 
FUND.—The term ‘qualified gigabit opportunity 
fund’ means any investment vehicle organized as a 
corporation or a partnership for the purpose of in-
vesting in qualified gigabit opportunity zone prop-
erty (other than another qualified opportunity fund) 
that holds at least 90 percent of its assets in quali-
fied opportunity zone property, determined— 
‘‘(A) on the last day of the first 6-month 
period of the taxable year of the fund, and 
‘‘(B) on the last day of the taxable year of 
the fund. 
‘‘(6) QUALIFIED GIGABIT OPPORTUNITY ZONE 
BUSINESS.— 
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‘‘(A) IN
GENERAL.—The term ‘qualified 
gigabit opportunity zone business’ means a 
trade or business— 
‘‘(i) in which substantially all of the 
tangible property owned or leased by the 
taxpayer is qualified gigabit opportunity 
zone business property, 
‘‘(ii) which satisfies the requirements 
of paragraphs (2), (4), and (8) of section 
1397C(b), and 
‘‘(iii) which is not described in section 
144(c)(6)(B). 
‘‘(B) SPECIAL
RULE.—For purposes of 
subparagraph (A), tangible property that ceases 
to be a qualified gigabit opportunity zone busi-
ness property shall continue to be treated as a 
qualified gigabit opportunity zone business 
property for the lesser of— 
‘‘(i) 5 years after the date on which 
such tangible property ceases to be so 
qualified, or 
‘‘(ii) the date on which such tangible 
property is no longer held by the qualified 
gigabit opportunity zone business. 
‘‘(e) APPLICABLE RULES.— 
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