Key Dates & Deadlines for Opportunity Zone Investing

As 2019 winds down and the full benefit of the Opportunity Zones tax incentive expires, here are some key dates for investing in Opportunity Zones — past and future.

Note: as IRS regulations are not yet finalized, these dates are subject to change.

February 2, 2017: The Investing in Opportunity Act is introduced in the Senate and House.

December 22, 2017: The Tax Cuts and Jobs Act of 2017 — which includes a modified version of the Investing in Opportunity Act — is signed into law, enacting the Opportunity Zones tax incentive.

January 1, 2018: The first date in which property may be acquired by purchase to qualify as eligible Qualified Opportunity Zone property.

June 14, 2018: Treasury finalizes certification of Opportunity Zones in all 50 states, 5 overseas territories, and the District of Columbia. There are 8,762 Opportunity Zones throughout the nation.

October 19, 2018: The first set of proposed regulations is issued by the IRS.

December 14, 2018: Treasury certifies two additional Puerto Rican Opportunity Zones, bringing the total number of OZs to 8,764.

February 14, 2019: The first IRS public hearing on Qualified Opportunity Funds.

April 17, 2019: The second set of proposed regulations is issued by the IRS.

June 28, 2019: The final date to invest capital gains recognized in 2018.

July 9, 2019: The second IRS public hearing on Qualified Opportunity Funds.

December 31, 2019: The final date to receive the full tax benefit of Opportunity Zone investing. After this date, the 15% step-up in basis after a 7-year hold goes away, as it is no longer possible to achieve a 7-year hold prior to the end of 2026.

June 27, 2020: The final date to invest capital gains recognized in 2019.

June 28, 2021: The final date to invest capital gains recognized in 2020.

December 31, 2021: The final date to receive any basis step-up on the original gain. After this date, the 10% step-up in basis after a 5-year hold goes away, as it is no longer possible to achieve a 5-year hold prior to the end of 2026.

June 28, 2022: The final date to invest capital gains recognized in 2021.

June 28, 2023: The final date to invest capital gains recognized in 2022.

June 27, 2024: The final date to invest capital gains recognized in 2023.

June 28, 2025: The final date to invest capital gains recognized in 2024.

June 28, 2026: The final date to invest capital gains recognized in 2025.

December 31, 2026: Original deferred gain is recognized.

April 15, 2027: Tax payments due on original deferred gain.

June 28, 2027: The final date to invest capital gains recognized in 2026, making this the final deadline to invest in a Qualified Opportunity Fund in order to achieve the 10-year gain exclusion.

2028: The first year in which some of the earliest Opportunity Zone investments may be sold and qualify for the 10-year gain exclusion.

December 31, 2028: Statutory expiration of the designation of Qualified Opportunity Zones. (It is unclear what, if any, material effect this will have on the incentive.)

June 28, 2037: The earliest date on which the last Opportunity Zone investments may be sold and qualify for the 10-year gain exclusion.

December 31, 2047: The final date to dispose of an Opportunity Zone investment (or possibly the final date to elect a basis step-up, rules still pending) in order to achieve a basis step-up to fair market value, thereby eliminating capital gains.