December 31, 2026.
Are you ready?
Every deferred gain invested under OZ 1.0 becomes taxable. The single most consequential deadline in the history of the Opportunity Zone program. Fund managers are on the front line, and many investors do not remember this is coming.
A defensible investor packet, ready before they need it
The new Form 8997, ready for their preparer. EIN, dates, deferred gain remaining, and the inclusion entry. Nothing to chase down.
A year-end statement with the December 31 value. Recognition is the lesser of remaining gain or fair market value. Only the fund can supply that number.
The K-1, on a stated timeline. It arrives with the fund's return in early 2027.
Proof the fund stayed qualified. The section 6039K statement with both 90% test results, in every investor's file before the IRS asks.
Clients invested in QOFs across many sponsors will need their 8997 reporting tracked and reconciled across every holding. The firms that can produce that reporting at scale will keep those clients. The firms that cannot will spend the season explaining why it is late.