Sec 1400Z-1 allowed each Governor to designate up to 25% of census tracts that either had poverty rates of at least 20% or median family incomes of no more than 80% of statewide or metropolitan area family income. There were 3,516 census tracts in 54 California counties that qualified under one or both of the mandatory criteria, which allowed Governor Brown to designate up to 879 tracts. After he did so the U.S. Department of the Treasury certified those 879 tracts as qualified opportunity zones. http://dof.ca.gov/Forecasting/Demographics/opportunity_zones/

California has not conformed to the tax benefits of QOZs, so any deferred gains reinvested under this program will be taxable in the sale year for California, and the basis of the investment in a QOF will be different for federal and state.