Defer the original gain
Defer recognition of eligible gain until the fifth anniversary of your investment, unless an earlier inclusion event occurs.
Turn a taxable gain into a long-term investment strategy. Explore a self-directed investment or a professionally managed private equity fund—with tax planning, structuring, and coordination built around your goals.
For eligible investments in a Qualified Opportunity Fund (QOF) made on or after January 1, 2027.
Defer recognition of eligible gain until the fifth anniversary of your investment, unless an earlier inclusion event occurs.
After five years, a basis increase generally excludes 10% of the deferred gain—or 30% for an investment in a qualified rural opportunity fund.
After at least ten years, an election can eliminate federal income tax on eligible QOF investment appreciation at exit. For holdings beyond 30 years, the basis adjustment uses the investment’s value at year 30.
Potential sources include taxable capital gains and eligible Section 1231 gains from transactions such as:
Generally, eligible gain must be invested within 180 days, with special timing rules for some transactions and pass-through entities. A failed exchange does not automatically restart that clock. Review timing before funds are released; ordinary income and related-party gains generally do not qualify.
Build your own QOF and investment structure around a property or business opportunity. Match the execution demands to your experience, liquidity, and long-term goals.
Acquire qualifying newly completed property before its first placement in service in the zone. This can avoid taking on ground-up development yourself. Pre-leasing or an appropriately structured tenant commitment may also reduce—and in some cases largely avoid—initial lease-up exposure.
Original use is a tax qualification test, not a risk rating. Prior use, placement-in-service timing, tenant arrangements, and any vacancy exception must be verified. An already occupied property does not qualify simply because it is new to you.
Reposition or renovate an existing property under a qualifying improvement plan. A successful transformation may offer a higher growth rate, alongside greater construction, budget, timing, financing, and leasing risk.
The required investment must satisfy the applicable improvement threshold within the 30-month period. Rural projects may qualify for a reduced threshold. Project economics and execution capacity should drive the decision.
A fund can put investment execution in a sponsor’s hands. We help investors and sponsors connect the structure, economics, and reporting to the intended tax outcome.
For real estate acquisition and disposition services, connect with Max Unger through Institutional Property Advisors, a division of Marcus & Millichap.
Explore STRCREBrokerage services are provided through the brokerage under a separate engagement.
Our Opportunity Zone White Paper discusses program benefits, qualification, investment strategies, estate planning, and state considerations.
Read the whitepaperThe whitepaper is dated January 2026. Confirm current guidance and zone eligibility before acting.
IRC §1400Z-2, including the 2027 amendments · IRS Notice 2026-40: transition guidance · IRS Opportunity Zone FAQs · IRS: sale of your home
Federal overview as of September 2026. Benefits depend on the investment date, qualifying gain, holding period, fund and property compliance, and required elections. Investment risk and state taxes remain relevant.
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