The April proposed regulations outlined three safe harbors that provided significantly more flexibility to QOZB's. Remember, the OZ legislation is about improving opportunities in OZs, so job-growth in designed opportunity zones matter much more than where the end-user of your products resides.
1. "At least 50 percent of the services performed (based on hours) for such business by its employees and independent contractors (and employees of independent contractors) are performed within the qualified opportunity zone"
2. "If at least 50 percent of the services performed for the business by its employees and independent contractors (and employees of independent contractors) are performed in the qualified opportunity zone, based on amounts paid for the services performed, the business meets the 50-percent
gross income test found in section 1397C(b)(2)."
3. "The proposed regulations provide that a trade or business may satisfy the 50-percent gross income requirement if (1) the tangible property of the business that is in a qualified opportunity zone and (2) the management or
operational functions performed for the business in the qualified opportunity zone are each necessary to generate 50 percent of the gross income of the trade or business."
In addition, "Taxpayers not meeting any of the other safe harbor tests may meet the 50-percent requirement based on facts and circumstances test if, based on all the facts and circumstances, at least 50 percent of the gross income of a trade or business is derived from the active conduct of a trade
or business in the qualified opportunity zone". Based on these tests/safe harbors, you need not worry too much about
fluctuations in monthly/annual income, so long as your primary employees are working in one or more OZs.