QOZ Planning Under the OBBBA

On July 4, 2025, President Trump signed the One Big Beautiful Bill Act into law, formally known as “H.R.1—An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14 ” (the OBBBA). The OBBBA includes provisions that establish a “second tranche” for the qualified opportunity zone (QOZ) and qualified opportunity fund (QOF) program that generally applies beginning on Jan. 1, 2027. This second tranche picks up following the conclusion of the initial QOZ/QOF program on Dec. 31, 2026, which marks the end of the original program’s investment period and the date when deferred gain is recognized under the 2017 Tax Cuts and Jobs Act (TCJA).

Here are the principal features of the second tranche in the context of QOZ planning that in…