The general rule is that mobile property will qualify as Qualified Opportunity Zone Business Property (QOZBP) if, based on the number of days between two consecutive testing dates, at least 70% of the property’s use is within an OZ. In addition, there is a safe harbor for property used by a business that meets the following requirements: (i) the property directly generates gross income for the business both inside and outside of the OZ; (ii) the business has an office or other facility within an OZ; (iii) the property is operated by employees of the business who (A) regularly use an OZ office of the business to carry out their duties and (B) are managed directly, actively, and substantially on a day-to-day basis by one or more employees of the business who carry out their duties at an office in the OZ; and (iv) the property is not operated entirely outside of an OZ for a period that is longer than 14 consecutive days to generate gross income. This safe harbor cannot be used to treat more than 20% of a business’ tangible property as QOZBP.
