Tools · For investors

Opportunity Zone deadline planner: December 31, 2026 vs OZ 2.0

Updated October 17, 2026 · Free, no sign-up, runs in your browser

The date you invest a gain in a Qualified Opportunity Fund decides which set of rules you get. Amounts invested after December 31, 2026 follow OZ 2.0 (P.L. 119-21, §70421(c)(5)(A)); anything invested on or before that date follows the original program. Enter your sale date to see both timelines side by side.

Related: 180-day rule calculator (day 1 for K-1, installment and REIT gains) · Step-up and 10-year exclusion calculator · OZ 2.0 nomination tracker

Your gain

Day 1 of your 180-day periodUsually the sale date. For K-1, installment or REIT gains, see the 180-day calculator.Capital gain to investThe amount you plan to defer.Federal tax rate on that gain20% top long-term rate + 3.8% NIIT = 23.8%.Planned QOF investment dateOn or before Dec 31, 2026 = OZ 1.0; Jan 1, 2027 or later = OZ 2.0.Fund type Qualified rural opportunity fundThe 30% rural step-up applies only to OZ 2.0 investments.

Your timeline

Day 180: last day to invest

Mar 13, 2027

Your 180-day period runs September 15, 2026 to March 13, 2027.

It crosses January 1, 2027, so the date you invest picks OZ 1.0 or OZ 2.0.

OZ 1.0 · invest by Dec 31, 2026

Invest between Sep 15, 2026 and Dec 31, 2026. Figures use Dec 31, 2026.

Tax on the deferred gain

$119,000

on your 2026 return, due Apr 15, 2027

Gain included: Dec 31, 2026 (or earlier if you sell)
Basis step-up: None
Amount included: $500,000 (before the value limit)
10-year election from: Dec 31, 2036
Exclusion limit: Not protected for sales after Dec 31, 2047
Zones: 2018 QOZs, designated through Dec 31, 2028

OZ 2.0 · invest from Jan 1, 2027 · your date

Invest between Jan 1, 2027 and Mar 13, 2027. Figures use Feb 1, 2027.

Tax on the deferred gain

$107,100

on your 2032 return, due Apr 15, 2033

Gain included: Feb 1, 2032 (or earlier if you sell)
Basis step-up: 10% of the deferred gain
Amount included: $450,000 (before the value limit)
10-year election from: Feb 1, 2037
Exclusion limit: Basis frozen at value on Feb 1, 2057 (30 years) if held longer
Zones: 2027 QOZs, Jan 1, 2027 to Dec 31, 2036

Key dates if you invest Feb 1, 2027

Sep 15, 2026
Day 1
Gain recognized
Feb 1, 2027
Invest in a QOF
OZ 2.0 rules
Mar 13, 2027
Day 180
Last day to invest
Feb 1, 2032
Gain included
after 10% step-up
Apr 15, 2033
Tax due
$107,100
Feb 1, 2037
10-year election
cap Feb 1, 2057

Dates assume a calendar-year individual and show April 15 without weekend or holiday shifts. Selling the QOF investment earlier moves the inclusion date up to the sale.

How this was calculated

Day 180 = day 1 + 179 days = Mar 13, 2027. Day 1 counts as the first day.
OZ 1.0: the deferred gain is included on Dec 31, 2026. A 2026 investment can't reach the 5-year hold by then, so there's no step-up. $500,000 × 23.8% = $119,000, due with your 2026 return on Apr 15, 2027.
OZ 2.0: inclusion is 5 years after the investment (Feb 1, 2032), after a 10% step-up: $500,000 × (1 − 10%) = $450,000; × 23.8% = $107,100, due Apr 15, 2033.
Difference: $11,900 less tax under OZ 2.0, paid about 6 years later, at the same rate.
If the investment is worth less than the deferred gain on the inclusion date, less is included (the fair-market-value limit).

Estimates only; not tax advice. Uses one federal rate you enter (for example 20% + 3.8% NIIT = 23.8%), ignores state tax and future rate changes, and shows April 15 without weekend or holiday shifts. Your inputs stay in your browser.

OZ 1.0 vs OZ 2.0: the rules that change on January 1, 2027

Rule	OZ 1.0: invested on or before Dec 31, 2026	OZ 2.0: invested after Dec 31, 2026
When deferred gain is included	Earlier of the sale of the investment or Dec 31, 2026 (IRC §1400Z-2(b)(1), text in effect for these investments; Treas. Reg. §1.1400Z2(b)-1(b))	Earlier of the sale or 5 years after the investment (§1400Z-2(b)(1)(B) as amended by P.L. 119-21, §70421(c)(2))
Basis step-up	10% after 5 years and another 5% after 7 years (§1400Z-2(b)(2)(B)(iii)-(iv)), counted only up to Dec 31, 2026, so an investment made after 2021 gets none	10% after 5 years; 30% for a qualified rural opportunity fund (§1400Z-2(b)(2)(B)(iii) as amended, §70421(c)(2)), treated as occurring before the 5-year inclusion date
Amount included	The lesser of the deferred gain or the investment's fair market value on the inclusion date, minus your basis (§1400Z-2(b)(2)(A); same text before and after amendment)
10-year rule	After 10 years, elect basis = fair market value on the date of sale (§1400Z-2(c)); protection after zones expire doesn't cover sales after Dec 31, 2047 (Treas. Reg. §1.1400Z2(c)-1(c))	After 10 years, basis = fair market value at sale if sold within 30 years; otherwise fair market value on the 30-year date (§1400Z-2(c)(A)-(B), §70421(c)(3))
Deferral election sunset	No election for sales or exchanges after Dec 31, 2026 (§1400Z-2(a)(2)(B), pre-2027 text)	Sunset repealed; the election is permanent (§70421(c)(1))

Key dates

Date	What happens	Source
July 4, 2025	P.L. 119-21 enacted. The 50% substantial improvement threshold for entirely rural zones takes effect.	P.L. 119-21, §70421(c)(5)(C)
July 1, 2026	First decennial determination date: states begin nominating tracts for 2027 zones (90-day period, plus an optional 30-day extension).	IRC §1400Z-1(c)(2); Rev. Proc. 2026-14, §2.02(3)(e)
October 28, 2026	Latest end of the nomination period with the extension. Requests to modify nominations after this date are denied.	Rev. Proc. 2026-14, §2.02(3)(e), §5.03
Nov 27 / Dec 28, 2026	Latest end of Treasury's 30-day certification period (December 28 if a state requests the extension).	Rev. Proc. 2026-14, §2.02(3)(f)
December 31, 2026	Last day to invest under OZ 1.0. All OZ 1.0 deferred gain still deferred is included in income on this date.	IRC §1400Z-2(b)(1)(B) (pre-2027 text); Treas. Reg. §1.1400Z2(b)-1(b)
January 1, 2027	2027 zones take effect. OZ 2.0 rules apply to amounts invested after December 31, 2026.	P.L. 119-21, §70421(c)(5)(A); Rev. Proc. 2026-14, §2.02(3)(g)
April 15, 2027	Calendar-year individual returns for 2026 are due, including OZ 1.0 deferred gain.	IRC §6072(a)
December 31, 2028	Designations of the 2018 zones end.	Rev. Proc. 2026-14, §2.02(2)(c)(i)
December 31, 2036	Designations of the 2027 zones end.	Rev. Proc. 2026-14, §2.02(3)(g)
December 31, 2047	For OZ 1.0 investments, the regulation that keeps the 10-year election available after zones expire doesn't cover sales after this date.	Treas. Reg. §1.1400Z2(c)-1(c)

Worked examples

1. A September 2026 sale: the window crosses the cutover

You sell stock on September 15, 2026 at a $500,000 long-term gain. Day 1 is September 15, 2026, so day 180 is March 13, 2027 (Treas. Reg. §1.1400Z2(a)-1(b)(7)). At a 23.8% federal rate (20% under IRC §1(h)(1)(D) plus 3.8% NIIT under §1411):

Invest by December 31, 2026 (OZ 1.0): the full $500,000 is included on December 31, 2026, so $119,000 of tax is due with your 2026 return on April 15, 2027.
Invest February 1, 2027 (OZ 2.0): inclusion is February 1, 2032. After the 10% step-up, $450,000 is included and $107,100 is due on April 15, 2033. The 10-year election is available from February 1, 2037; past February 1, 2057, basis is frozen at that date's value. In a qualified rural fund the step-up is 30%: $350,000 included, $83,300 tax.

2. A May 2026 sale: OZ 1.0 only

Day 1 is May 1, 2026, so day 180 is October 27, 2026. The whole window ends before January 1, 2027, so any QOF investment of that gain follows OZ 1.0 and is included on December 31, 2026.

FAQ

What changes for Opportunity Zone investors on January 1, 2027?

P.L. 119-21 §70421(c)(5)(A) applies the new deferral, step-up and 10-year rules to amounts invested in QOFs after December 31, 2026. An investment made on or before December 31, 2026 keeps the original rules: the deferred gain is included on December 31, 2026, and no step-up is left for new investments. An investment on or after January 1, 2027 defers the gain for 5 years and gets a 10% step-up after 5 years (30% for a qualified rural opportunity fund). Not tax advice.

If I sold in late 2026, can I still get OZ 2.0 treatment?

Yes, if your 180-day period runs past December 31, 2026 and you invest on or after January 1, 2027. The 180-day period begins on the day the gain would be recognized (Treas. Reg. §1.1400Z2(a)-1(b)(7)), so for a sale it runs from the sale date through day 180. Gains with day 1 on or after July 6, 2026 have a day 180 in 2027.

When is tax due on an OZ 1.0 deferred gain?

The gain is included in income on December 31, 2026 (IRC §1400Z-2(b)(1)(B) as in effect for those investments; Treas. Reg. §1.1400Z2(b)-1(b)(2)), so it goes on your 2026 return, due April 15, 2027 for calendar-year individuals (IRC §6072(a)). The amount included is the lesser of the deferred gain or the investment's fair market value, minus your basis (§1400Z-2(b)(2)(A); Reg. §1.1400Z2(b)-1(e)(3)).

When is tax due on an OZ 2.0 deferred gain?

In the tax year that includes the earlier of the date you sell the investment or the date 5 years after you made it (IRC §1400Z-2(b)(1), as amended by P.L. 119-21 §70421(c)(2)). An investment made February 1, 2027 is included on February 1, 2032 and reported on the 2032 return, due April 15, 2033.

Which zones can I invest in?

The 2018 zones stay designated through December 31, 2028. The new 2027 zones are in effect from January 1, 2027 through December 31, 2036 (Rev. Proc. 2026-14, sections 2.02(2)(c) and 2.02(3)(g)). As of October 17, 2026, Treasury has not yet published the certified 2027 list; see our nomination tracker.