The Opportunity Zone (OZ) program is changing, and the window to act under the existing rules is closing fast. IRS Notice 2026-40, issued in response to the One Big Beautiful Budget Act (OBBBA), gives investors, developers, and fund managers the clearest picture yet of how the program evolves as the 2026 inclusion event approaches and a new compliance regime takes effect in 2027.
This video breaks down what this guidance means for existing and future OZ positions by examining the 2026 inclusion event and its impact on Qualified Opportunity Fund (QOF) holders, how updated working capital safe harbor thresholds affect fund operations, how transitional rules impact project structuring decisions and how the post-2026 framework changes deferral mechanics and qualification standards.
Viewers will get a clear picture of what to do — and what to watch — before the rules shift.
By watching, viewers will:
- Describe the key provisions of IRS Notice 2026-40 and how they impact OZ investments
- Distinguish between the current OZ framework and the post-2026 rules under OBBBA, including revised deferral mechanics and qualification standards
- Explain how the 2026 inclusion event affects existing QOF investments
- Evaluate how transitional rules impact project structuring, including development, expansion and capital planning
- Compare standard and rural opportunity fund basis step-up thresholds and identify which investments qualify under each track
