To provide CPAs and tax professionals with a clear, practical understanding of Qualified Opportunity Zone investment rules—including recent OBBBA changes—so they can accurately apply tax benefits, comply with fund requirements, and support informed planning and advisory decisions.

• Definition and mechanics of an investment in a Qualified Opportunity Zone (QOZ) under the 2017 Tax Cuts and Jobs Act (TCJA)
• Key changes to QOZ investment policies under the OBBBA
• Tax benefits and gain deferral available to investors under the original QOZ law, including relevant examples
• Operating rules for Qualified Opportunity Funds (QOFs)
• Changes to QOF rules under the OBBBA, including effective dates and timing
• Operating rules related to Partnerships and Corporations that operate as a QOF

To provide CPAs and tax professionals with a clear, practical understanding of Qualified Opportunity Zone investment rules—including recent OBBBA changes—so they can accurately apply tax benefits, comply with fund requirements, and support informed planning and advisory decisions.

DETAILED LEARNING OBJECTIVES

• Identify the statutory definition and purpose of Qualified Opportunity Zones (QOZs)

• Explain the timing requirements for investing eligible gain into a Qualified Opportunity Fund (QOF), including the 180-day investment window

• Describe current 2026 OBBBA rules governing QOF benefits, including updates to gain deferral, basis adjustments, and rural incentives

• Apply updated gain recognition rules for deferred gain on December 31, 2026, and determine post-2026 gain exclusion for long-term QOF investments

• Identify eligible types of gains that may be deferred through a QOF, including capital gains, short-term gains, and Section 1231 gains

• Understand partnership-level and partner-level rules for deferral elections, including when a partnership may elect deferral and when partners may make their own elections

• Explain the 90% asset test for QOFs and how OBBBA updates affect QOF property qualification, including treatment of QROF-eligible property

• Distinguish the requirements for QOZ stock and QOZ partnership interests, including acquisition tests, organizational requirements, and “substantially all” operational requirements

• Determine the asset requirements for a QOZ business, including the 70% QOZ property threshold and restrictions on prohibited businesses

• Describe the QOZ business working capital safe harbor, including the requirement for a written plan and the 31-month timeline

• Apply substantial improvement requirements to QOZ property under updated OBBBA rules, including exceptions for rural, unused, or exempt property

• Explain QOF self-certification rules, including filing requirements for Form 8996

• Calculate potential penalties for failing the 90% asset test and understand how penalties are determined on Form 8996

• Analyze regulatory guidance addressing the 50% gross income test for QOZ businesses, including safe harbors and facts-and-circumstances criteria

• Definition and mechanics of an investment in a Qualified Opportunity Zone (QOZ) under the 2017 Tax Cuts and Jobs Act (TCJA)
• Key changes to QOZ investment policies under the OBBBA
• Tax benefits and gain deferral available to investors under the original QOZ law, including relevant examples
• Operating rules for Qualified Opportunity Funds (QOFs)
• Changes to QOF rules under the OBBBA, including effective dates and timing
• Operating rules related to Partnerships and Corporations that operate as a QOF