IRS Notice 2026-55: request for comments on OZ 2.0 investment rules
Notice 2026-55 requests comments on issues under section 1400Z-2 as amended by section 70421 of Public Law 119-21 (the One, Big, Beautiful Bill Act), including whether more guidance is needed on investments in qualified opportunity funds and on fund investments in qualified opportunity zone businesses.
The notice restates the OZ 2.0 step-up: if an investment is held at least five years, basis increases by 10 percent of the deferred gain, or 30 percent for an investment in a qualified rural opportunity fund (QROF).
Topics include the 180-day investment period, inclusion events, the 90-percent investment standard, QOZB requirements, the working capital safe harbor, leased property, original use and substantial improvement.
Written comments should be submitted by November 23, 2026, at regulations.gov (docket IRS-2026-1156) or by mail. The IRS announced the notice on September 22, 2026.
Primary sources
On Opportunity Zone Invest
- Our coverage: IRS Notice 2026-55 seeks comments on OZ 2.0 homebuilding, working capital and the 30-year rule
- Our coverage: Rural 30% step-up: what Notice 2026-55 says, and what it is worth on a $500K gain
Checked against the source on October 14, 2026. This page summarizes the official document; it is not tax advice.