Illustration of the IRS Opportunity Zone transition — an urban skyline with a December 31 clock over a development blueprint
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IRS Opportunity Zone Transition Rules 2026: Notice 2026-40

Does the new Opportunity Zone regime just extend the old rules? No. The IRS Opportunity Zone transition rules in Notice 2026-40 keep the December 31, 2026 deferred-gain date, but reinvested QOF gains restart the 10-year clock and ongoing projects now need a written working-capital plan in place by year-end. The IRS has finally drawn a…

Illustration of Qualified Opportunity Zones under IRS Notice 2026-40 — a city skyline on a map pin with a 2026 calendar marking the deferred-gain inclusion deadline
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QOZ Update: IRS Notice 2026-40 and the Dec 31, 2026 Deadline

Are the Opportunity Zone rules changing? Yes. In IRS Notice 2026-40, the Treasury Department and the IRS announced that they intend to issue proposed regulations on Qualified Opportunity Zones under Internal Revenue Code §§ 1400Z-1 and 1400Z-2, as amended by the One, Big, Beautiful Bill Act (OBBBA). The notice provides transitional guidance for investments made…