Overview
Gateway Opportunity Zone Fund II acquires and develops sites inside designated Opportunity Zones across six growth markets. Investors reinvest a realized capital gain within 180 days to defer the tax, and a ten-year hold makes the fund's own appreciation federally tax-free on exit.
This is development capital. Expect limited income during construction and lease-up, with returns concentrated at the back-end sale. The 2025 law made the program permanent and reset the deferral rules for investments from 2027 forward.
Gallery

Highlights
- Accepts capital gains from any source, not just real estate.
- Ground-up multifamily and mixed-use across six markets.
- Ten-year hold targets tax-free appreciation on exit.
- Target IRR of 13–15%, back-loaded to disposition.
Illustrative Value Growth (per $100k)
Illustrative fund value showing the development J-curve; income is minimal until stabilization, with value concentrated at the ten-year exit. Not a forecast.
Benchmark Analysis
| Metric | This Offering | Peer Average |
|---|---|---|
| Target IRR | 13–15% | 12% |
| Projected equity multiple | 2.4x | 2.1x |
| Hold to full benefit | 10 yrs | 10 yrs |
Compared to the average multi-market OZ development fund. Illustrative, net of fees.
Features
Offering Details
| Offering type | Qualified Opportunity Fund |
|---|---|
| Strategy | Ground-Up Development · 6 Markets |
| Sponsor | Baker Real Estate Partners |
| Target IRR | 13–15% (net, at exit) |
| Minimum investment | $50,000 |
| Reinvestment window | 180 days from the gain |
| Hold for full benefit | 10 years |
| Offering exemption | Reg D 506(c) · accredited only |
Program Rules: OZ 1.0 vs OZ 2.0
| Deferral of rolled-in gain | Until the 2026 recognition date |
|---|---|
| Interim basis step-up | 10% at 5 yrs / 5% at 7 yrs (expired) |
| 10-year appreciation | Tax-free |
| Rural incentive | None |
| Program status | Original TCJA (2017), time-limited |
| Deferral of rolled-in gain | Rolling 5-year window |
| Interim basis step-up | 10% standard / 30% rural |
| 10-year appreciation | Tax-free |
| Rural incentive | Enhanced; 50% improvement threshold |
| Program status | Permanent (2025 law) |
Illustrative summary of the two rule sets; confirm current law with your CPA.
Documents
Analyst Notes
A credible OZ development fund for patient, gain-deferring capital. Best suited to investors who can leave the money alone for the full decade.
Pros. Broad gain eligibility, experienced development team, geographic diversification, and the signature ten-year tax-free exit.
Cons. Construction and lease-up risk, little current income, a long lock-up, and outcomes sensitive to rates and local absorption.