Michael Cohn reports in Accounting Today that PwC's James Montague says OZ 1.0 investors heading into year-end are discovering incorrect, incomplete, or missing Opportunity Zone reporting forms — including investor Form 8997 and fund Form 8996 — with tax and financial-reporting consequences even when the investment otherwise met the statute. A July PwC comment letter to Treasury and the IRS warned that, under a straight-to-final regulation, a statutorily compliant investor can be forced to recognize the entire deferred gain solely because of a bad or missing reporting form, with only an amended return, an administrative adjustment request, or an undefined showing to the Commissioner as remedies. Montague also flags Notice 2026-40: to keep investing in OZ 1.0 tracts that are not certified again under 2.0, funds must satisfy specified requirements by the end of 2026 or those zones are closed for new investment, earlier than the 2028 1.0 map sunset many sponsors expected. The rural 30% five-year step-up is all-or-nothing: a QOF must hold at least 90% of its investments in rural tracts to get 30%; otherwise the investor-level step-up is 10%. Governors' nomination window runs through September 28, 2026 (extension October 28, 2026 under IRS Rev. Proc. 2026-14); if every extension is used, Montague said the latest the new tract list could be known is December 28, 2026. OZ 2.0 investments on or after January 1, 2027 follow the rolling five-year deferral and 10% (30% rural) step-up. This is a 9/3 PwC/Accounting Today reporting-and-transition story, not the August 31 deferred-gain tax-bill item.
Original reporting by the OpportunityZoneInvest Editorial Team for Opportunity Zone Invest, an independent OZ 2.0 research site. Facts are drawn from the primary sources cited above per our editorial standards. Nothing here is tax, legal, or investment advice.
OZ tools: Opportunity Zone calculator · OZ 2.0 likelihood checker · 180-day rule calculator · Form 8997 instructions · Form 8996 instructions · all tools
Track OZ 2.0 as it happens
One email when major Opportunity Zone 2.0 events happen — Treasury guidance, state filings, and rule changes.