It means a trade or business in which substantially all of the tangible property owned or leased by the taxpayer is qualified opportunity zone business property, defined as follows:
- The business acquired the property by purchase from unrelated persons after December 31, 2017.
- The original use of the property commences with the business, or the business substantially improves the property.
- During substantially all of the business’s holding period for such property, substantially all of the use of that property was in the Opportunity Zone.
- At least 50% of the taxpayer’s total gross income is derived from the active conduct of such business.
- A substantial portion of the intangible property of the taxpayer is used in the active conduct of such business.
- Less than 5% of the average of the aggregate unadjusted bases of the taxpayer’s property is attributable to nonqualified financial property.