ValueCapital-gains deferral (rolling 5-yr for post-2026 investments) plus 10% basis step-up after 5 yrs (30% for rural Qualified Rural Opportunity Funds) and full exclusion of QOF appreciation after 10 yrs; made permanent by OBBBA
DeadlinesNew zone designations take effect 1/1/2027 (designation window ran from 7/1/2026); existing zones usable for new investments through 12/31/2028 overlap
RequirementsInvest realized capital gains into a Qualified Opportunity Fund within 180 days; QOF deploys into QOZ business property; substantial-improvement rules (50% threshold in rural zones)
Caveats2027 map shrinks ~20-25% and targets lower-income tracts — verify each facility's census tract under both current and 2027 designations; IRS regs for OZ 2.0 still being issued; requires QOF structuring/tax counsel
Last verified2026-08-23