A new provision in the Tax Cuts and Jobs Act lays the foundation for placing trillions of dollars in unrealized capital gains into investment funds to drive long-term capital to distressed communities. The new Opportunity Zone Program provides tax benefits in Opportunity Funds, or "O Funds." O Funds will activate passive holdings by connecting investors to investment opportunities in Opportunity Zones. This concept, which was originally introduced in the Investing in Opportunity Act, is the first new community development tax incentive program introduced since the Clinton Administration.