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139 STAT. 226 PUBLIC LAW 119–21—JULY 4, 2025 ‘‘(i) QUALIFIED RURAL OPPORTUNITY FUND.—The term ‘qualified rural opportunity fund’ means a quali- fied opportunity fund that holds at least 90 percent of its assets in qualified opportunity zone property which— ‘‘(I) is qualified opportunity zone business property substantially all of the use of which, during substantially all of the fund’s holding period for such property, was in a qualified opportunity zone comprised entirely of a rural area, or ‘‘(II) is qualified opportunity zone stock, or a qualified opportunity zone partnership interest, in a qualified opportunity zone business in which substantially all of the tangible property owned or leased is qualified opportunity zone business property described in subsection (d)(3)(A)(i) and substantially all the use of which is in a qualified opportunity zone comprised entirely of a rural area. For purposes of the preceding sentence, property held in the fund shall be measured under rules similar to the rules of subsection (d)(1). ‘‘(ii) RURAL AREA.—The term ‘rural area’ means any area other than— ‘‘(I) a city or town that has a population of greater than 50,000 inhabitants, and ‘‘(II) any urbanized area contiguous and adja- cent to a city or town described in subclause (I).’’. (3) SPECIAL RULE FOR INVESTMENTS HELD AT LEAST 10 YEARS.—Section 1400Z-2(c) is amended by striking ‘‘makes an election under this clause’’ and all that follows and inserting ‘‘makes an election under this subsection, the basis of such investment shall be equal to— ‘‘(A) in the case of an investment sold before the date that is 30 years after the date of the investment, the fair market value of such investment on the date such investment is sold or exchanged, or ‘‘(B) in any other case, the fair market value of such investment on the date that is 30 years after the date of the investment.’’. (4) DETERMINATION OF QUALIFIED OPPORTUNITY ZONE PROP- ERTY.— (A) QUALIFIED OPPORTUNITY ZONE BUSINESS PROP- ERTY.—Section 1400Z-2(d)(2)(D)(i)(I) is amended by striking ‘‘December 31, 2017’’ and inserting ‘‘the applicable start date (as defined in section 1400Z-1(e)(2)) with respect to the qualified opportunity zone described in subclause (III)’’. (B) QUALIFIED OPPORTUNITY ZONE STOCK AND PARTNER- SHIP INTERESTS.—Section 1400Z-2(d)(2) is amended— (i) by striking ‘‘December 31, 2017,’’ each place it appears in subparagraphs (B)(i)(I) and (C)(i) and inserting ‘‘the applicable date’’, and (ii) by adding at the end the following new subparagraph: ‘‘(E) APPLICABLE DATE.—For purposes of this subpara- graph, the term ‘applicable date’ means, with respect to Definition.