An ArentFox Schiff alert lays out the estate-planning angle on Qualified Opportunity Zones after the One Big Beautiful Bill Act, noting that most QOZ estate-planning rules from the 2017 law carry over largely unchanged. It covers the treatment of QOF interests at death, planning with gifts and grantor trusts, and holding-period considerations for heirs, alongside the December 31, 2026 deferred-gain recognition date (measured against the lower of the deferred gain or the fund interest's fair market value). One permanent change: OBBBA locks in the 10% five-year basis step-up but eliminates the former additional 5% step-up, capping the in-hold basis benefit at 10%. The takeaway: OZ is now a durable estate-planning tool, but the mechanics require careful, ongoing tracking of QOF interests.
Original reporting by Daniel Cho 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.
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