development initiatives, and (3) (A) are poised for economic growth that requires access to high speed broadband for commercial purposes, and (B) represent the areas of a State where such service would result in the highest return on investment. (e) Number of designations (1) In general Except as provided by paragraph (2), the number of population census tracts in a State that may be designated as qualified gigabit opportunity zones under this section may not exceed 25 percent of the number of low-income communities in the State. (2) Exception If the number of low-income communities in a State is less than 100, then a total of 25 of such tracts may be designated as qualified gigabit opportunity zones. (f) Designation of tracts contiguous with low-Income communities (1) In general A population census tract that is not a low-income community may be designated as a qualified gigabit opportunity zone under this section if— (A) such tract meets the requirements of paragraph (1) of subsection (a), (B) the tract is contiguous with the low-income community that is designated as a qualified gigabit opportunity zone, and (C) the median family income of the tract does not exceed 150 percent of the median family income of the low-income community with which the tract is contiguous. (2) Limitation Not more than 25 percent of the population census tracts designated in a State as a qualified gigabit opportunity zone may be designated under paragraph (1). (g) Period for which designation is in effect A designation as a qualified gigabit opportunity zone shall remain in effect for the period beginning on the date of the designation and ending at the close of the 7th calendar year beginning on or after such date of designation. 1400Z–2. Deferral for eligible taxpayer of capital gains invested in gigabit opportunity zones (a) In general (1) Exclusion of gain invested in gigabit opportunity zone property In the case of gain from the sale to, or exchange with, an unrelated person of any property held by an eligible taxpayer, at the