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ARTICLE · 23 OCTOBER 2026

QOZ 2.0 Is Coming. Are You Ready?

The One Big Beautiful Bill Act transforms the qualified opportunity zone program by removing its 2026 expiration date and introducing enhanced incentives for long-term investments. Investors now face critical decisions about timing their 2026 gains, navigating new zone designations, and structuring funds to maximize tax benefits including a potential 30% basis increase for rural investments.

United StatesTax

Overview

Since 2017, the opportunity zone program has offered investors an unusual combination of tax deferral and tax elimination, but always with an expiration date attached. For investments made after December 31, 2026, the One Big Beautiful Bill Act (OBBBA) removes that expiration date, making the qualified opportunity zone (QOZ) program permanent and adding new incentives for long-term investment. The revised program, commonly called QOZ 2.0, generally applies to investments made on or after January 1, 2027. For investors with 2026 gains, it is possible to get the benefit of this new program.

In depth

Five year tax deferral for every investment

Under QOZ 2.0, an investor generally may defer paying US federal income tax on eligible gain invested in a qualified opportunity fund (QOF) until five years after the investment, unless a sale or other inclusion event occurs first. An investment held for at least five years also receives a basis increase equal to 10% of the deferred

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