About 1 in 4 funds we see comes with a compliance issue. The managers are careful people, and most of them are surprised when it turns up. Many of the issues trace back to cash: where it sat, on which date, and what paperwork covered it. Why cash causes the trouble A building in a zone qualifies and stays that way. Cash is different. The same dollar can pass on one testing date and fail on the next, depending on which entity holds it and how long it has been there. Cash also moves faster...

On September 11, 2026, Treasury and the IRS published proposed regulations REG-116506-25. The proposal sets out how the reporting requirements in the OBBBA will work in practice. It runs 121 pages. These are proposed rules. They would apply to returns and statements due after final regulations are published, and current rules govern until then. Comments are due October 26, 2026. Three changes matter most for the annual work on a fund. Every QOZB reports to its QOF This is the biggest change...

What QOF managers and their CPAs should be assembling now, before the instructions arrive. The IRS quietly published an early-release draft of the 2026 Form 8997 on August 4, 2026. The instructions have not been released, and draft forms may not be filed. The structure is worth reading now. Much of what changed is built around the end of the deferral period on December 31, 2026, which reaches every investor who put a gain into a QOF before 2027. Part III now carries the computation. The 2025...