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...

Where a single entity holding both legacy and post-2026 capital runs into the transition rules. We are hearing a version of this question every week. A sponsor holds a 2019 or 2021 QOF that is still deploying, and wants to use that same entity to raise fresh capital once the new zones take effect on January 1, 2027. Nothing in the statute or in Notice 2026-40 requires a new entity. The practical answer is harder. A dual-vintage fund runs two property regimes, two benefit schedules, and two...

Transitional guidance on Qualified Opportunity Zones under OZ 2.0: what fund managers and investors need to know now. On June 18, 2026, the IRS issued Notice 2026-40. This Notice is transitional guidance ahead of forthcoming proposed regulations. It resolves several timing and compliance questions created by the OBBBA. The positions below are reliable for planning today. They are not yet final regulations, so you should confirm current guidance before acting. The December 31, 2026...