IRC § 1400Z-2 Opportunity Zones
26 U.S.C. § 1400Z-2
Enacted by the 2017 Tax Cuts and Jobs Act, this statute lets a taxpayer elect to defer eligible capital gain by reinvesting it in a Qualified Opportunity Fund (QOF) within 180 days of the sale; a QOF must hold at least 90% of its assets in qualified opportunity zone property, and a QOF interest held at least 10 years permits exclusion of post-investment appreciation via a fair-market-value basis step-up. For investments made through December 31, 2026, deferred gain is recognized on the earlier of disposition of the QOF interest or December 31, 2026. The One Big Beautiful Bill Act (Pub. L. 119-21, July 4, 2025) made the program permanent and, for investments made after December 31, 2026, replaced the fixed 2026 deadline with a rolling five-year deferral.
Who must comply
Other IRS regulations
Section 1031 Real Property Definition
26 CFR § 1.1031(a)-3
Deferred Like-Kind Exchange Rules
26 CFR § 1.1031(k)-1
Opportunity Zone Final Regulations
26 CFR §§ 1.1400Z2(a)-1 through 1.1400Z2(f)-1
IRC § 1031 Like-Kind Exchanges
26 U.S.C. § 1031
IRC § 1250 Depreciation Recapture
26 U.S.C. § 1250
FIRPTA Withholding
26 U.S.C. § 1445; 26 CFR § 1.1445-1
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