"Even though I think it's clear that it was designed to have a broader application and to pick up operating businesses, I think they [Opportunity Zones] are not great for that application," Sharkey says. "I think it's a tool that doesn't have a great fit."

The length of the investment is one of the reasons for this 

"One of the things that make real estate investments such a good match for Opportunity Zones is that they are long-term assets," Sharkey says. "Real estate projects are much more likely to have a box around them that you can steer out of."

But a lot of things can happen to a startup over a decade. "For a startup business, ten years is a long time," Sharkey says. 

Mike Krueger, a partner at Newmeyer Dillion, does see a path for OZ investments into startups. "I think that's one of the easier transactions to do is working with companies who are looking to raise capital," he says. "Startup companies are just as good of an Opportunity Zone deal as real estate. I think a lot of people forget that it doesn't have to be a real estate deal for an opportunity."

In fact, Krueger thinks Opportunity Zone Fund investments in operating businesses will grow in popularity. "It can be any type of business, and I think we're going to see that increase," he says. 

Some of that money could come from funds earmarked for foreign investment. "I think people are now reconsidering a lot of foreign investments—money that people were taking out of the US economy to put into foreign investments," he says. " I think [now] they invest that money domestically. We're going to see more money staying in the US and being put into local projects."