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National Law Review
National Law Review
7/20/2026
The original headline is: "Treasury Provides Transition Roadmap for Opportunity Zones 2.0"

The original headline is: "Treasury Provides Transition Roadmap for Opportunity Zones 2.0"

Original: Treasury Provides Transition Roadmap for Opportunity Zones 2.0

Short summary

Treasury released Notice 2026-40, providing the first practical transition roadmap from Opportunity Zone 1.0 to OZ 2.0. OZ 1.0 deferred gains come due Dec. 31 and cannot be rolled into OZ 2.0, though selling before year-end allows reinvestment. Certain 2026 capital gains may qualify for OZ 2.0 if invested during a 2027 window. Investors should review positions, pending projects, and 2026 gains before year-end.

  • OZ 1.0 deferred gains recognized Dec. 31; cannot roll into OZ 2.0 unless sold beforehand
  • 2026 capital gains may qualify for OZ 2.0 if invested during the 2027 portion of the 180-day window
  • Investors should review working capital safe harbors, new tract designations, and Rural QOF benefits

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