The Opportunity Zone legislation has already unleashed considerable activity, with real estate companies starting to establish new funds. : Real estate fund sponsors are lining up to capture private equity poised to flow into new Opportunity Zones created by the Tax Cut and Jobs Act. The basic premise behind the Opportunity Zones initiative was to offer incentives in the form of deferred and reduced taxes on capital gains to attract private capital for investment in low-income urban, suburban and rural areas of the country.