Opportunity Zones
Opportunity Zone Deadlines and Cost Segregation Dates, 2026–2028
By Howard Krieger, MBA, former ASA, Managing Director, ClickDrag Finance. Updated .
For an investor still holding a qualifying QOF investment made on or before December 31, 2026, the remaining deferred gain is included in income for the tax year that includes December 31, 2026 (a calendar-year investor’s 2026 return) under Notice 2026-40 section 4.01, unless an earlier inclusion event already triggered it. This Opportunity Zone and cost segregation calendar lists the dates from 2026 through 2028 that calendar-year Opportunity Zone funds, their investors and property owners plan around, and each date links to the IRS notice, revenue procedure, statute or regulation that sets it.
Cost segregation runs on the same calendar: for a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31 is first depreciated on that year’s return, and the return due dates below are when a cost segregation study’s depreciation, and any Form 3115 for an automatic accounting-method change, goes on a return.
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General information, not tax advice; confirm dates with your tax adviser.
What are the upcoming Opportunity Zone and cost segregation dates?
The dates are for calendar-year taxpayers. Filing deadlines already account for weekends and legal holidays under IRC §7503; testing dates and the ends of designation periods do not move.
Zone map
Latest end of Treasury’s 2027 OZ designation window
Under Rev. Proc. 2026-14 section 2.02(3)(f), Treasury’s 30-day window to certify and designate a nominated tract as a 2027 Opportunity Zone ends November 27, 2026 at the latest, unless the governor requested a further 30-day extension. The window runs from the date Treasury receives the nomination, so it can end earlier, and the new map is final only when Treasury designates the tracts.
Zone map
Extended outer date for 2027 OZ designations
Under Rev. Proc. 2026-14 section 2.02(3)(f), when a governor requests the further 30-day extension, Treasury’s window to designate that state’s 2027 Opportunity Zones runs to December 28, 2026 at the latest. The extension applies only on the governor’s request; it is not automatic.
Depreciation
Placed in service by Dec 31 (calendar-year taxpayers)
For a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31 is first depreciated on that year’s return, and property placed in service on January 1 or later is first depreciated on the next year’s return. A cost segregation study on that property can be completed after year-end, before the return is filed; buying or placing property in service for the deduction alone is not a reason to do either.
Placing property in service by December 31 for cost segregation
Investor
Pre-2027 QOF deferred gain included in income (if held)
For an investor still holding a qualifying QOF investment made on or before December 31, 2026, the remaining deferred gain is included in income for the tax year that includes December 31, 2026, unless an earlier inclusion event already triggered it (Notice 2026-40 section 4.01; prior §1400Z-2(b)(1)). The amount included is the lesser of the deferred gain or the investment’s fair market value on that date, minus the investor’s basis in the investment (§1400Z-2(b)(2)); the investor keeps the investment and can still make the 10-year election under §1400Z-2(c) after a 10-year hold.
The 2026 Opportunity Zone deferred-gain tax bill
Source: IRS Notice 2026-40, section 4.01
Fund
2018-only tract property cutoff (exceptions apply)
Under Notice 2026-40 section 5.01(1), tangible property a QOF or QOZ business acquires after December 31, 2026 cannot be qualified opportunity zone business property unless it is acquired for use in a zone designated after July 4, 2025 or one of two exceptions applies (a working capital safe harbor plan meeting the 2026 thresholds, or ordinary-course replacement property). Property acquired on or before December 31, 2026 in a 2018 tract is tested under the existing designation, which runs through December 31, 2028 (Puerto Rico: December 31, 2027).
Fund
OZ working capital plan: adopt, 10% in, 5% spent
Under Notice 2026-40 section 5.01(2)(b), property a QOZ business acquires after December 31, 2026 for use in a previously designated zone can meet the acquisition requirement only if the written working capital safe harbor plan was adopted on or before December 31, 2026, the business received at least 10% of the planned working capital by that date and spent at least 5% by that date, and later acquisitions are substantially consistent with the plan. Amounts the business must spend under a binding agreement entered into before January 1, 2027 count as spent for the 5% test.
Fund
QOF 90% asset test: year-end testing date
For a calendar-year qualified opportunity fund, the last day of the tax year, December 31, is one of the two dates whose average must show at least 90% of assets in qualified opportunity zone property (§1400Z-2(d)(1)). The values are reported on Form 8996 with the fund’s return.
Source: IRC §1400Z-2(d)(1)
Investor
OZ 2.0 rules apply to new QOF investments
For amounts invested in a qualified opportunity fund after December 31, 2026, deferred gain is included at the earlier of a sale or exchange or 5 years after the investment, and an investment held at least 5 years gets a basis increase of 10% of the deferred gain (30% for a qualified rural opportunity fund) (§1400Z-2(b) as amended by OBBBA §70421(c)). After a 10-year hold, the §1400Z-2(c) election sets basis at fair market value on the earlier of the sale or 30 years after the investment; each of these dates runs from the investor’s own investment date, not a fixed calendar date.
Zone map
2027 Opportunity Zones take effect
Under Rev. Proc. 2026-14 section 2.02(3)(g), a tract Treasury certifies and designates in the 2026 round is an Opportunity Zone from January 1, 2027 through December 31, 2036. The 2018 zones are not removed by it: under section 2.02(2)(c) they stay designated through December 31, 2028 (Puerto Rico: December 31, 2027).
Return or payment due
Fourth 2026 estimated tax installment due
For a calendar-year individual, the fourth 2026 estimated tax installment is due January 15, 2027; the 2026 tax that the 90% current-year test measures includes any deferred Opportunity Zone gain included for 2026, but an individual whose installments meet the prior-year safe harbor of §6654(d)(1)(B), measured on the 2025 tax, is not required to pay more for it. That installment is not required if the 2026 return is filed by February 1, 2027 and the entire balance is paid with it (Form 1040-ES).
Source: IRS Form 1040-ES (2026)
Return or payment due
2026 partnership and S corporation returns due
For a calendar-year partnership or S corporation, the 2026 return (Form 1065 or 1120-S) is due March 15, 2027, and a QOF taxed as a partnership or S corporation attaches Form 8996 to it; Form 7004 gives an automatic 6-month extension of time to file, not to pay. An automatic accounting-method change on Form 3115 (for example, catch-up depreciation after a cost segregation study on property the partnership or S corporation placed in service in an earlier tax year and still owns, when it meets the conditions in section 6.01 of Rev. Proc. 2025-23) is attached to the timely filed original return for the year of change, including extensions (Rev. Proc. 2015-13 section 6.03(1)(a)).
The 2027 tax deadlines for a cost segregation study
Source: IRC §6072(b)
Return or payment due
2026 individual and C corporation returns due
For a calendar-year individual or C corporation, the 2026 return is due April 15, 2027, and any tax owed is due that day even with an extension, which is an extension of time to file, not to pay. For an investor still holding a pre-2027 QOF investment, this 2026 return reports the deferred gain included for 2026 on Form 8949 and Schedule D, with Form 8997 attached; a C corporation QOF attaches Form 8996.
The 2027 tax deadlines for a cost segregation study
Source: IRC §6072(a)
Fund
QOF 90% asset test: six-month testing date
For a calendar-year qualified opportunity fund that has been a QOF since the start of its tax year, June 30 is the last day of the first 6-month period and one of the two §1400Z-2(d)(1) testing dates for the 90% asset test. A fund that first became a QOF partway through the year starts its 6-month period in that first month, so its date differs (Form 8996 instructions).
Source: Instructions for Form 8996
Return or payment due
Extended 2026 partnership and S corp returns due
For a calendar-year partnership or S corporation that filed Form 7004, the extended 2026 return is due September 15, 2027; the extension was of time to file, not to pay. A Form 8996 for a QOF taxed as a partnership or S corporation, and any Form 3115 for an automatic change for property the entity placed in service in an earlier tax year and still owns (when it meets the conditions in section 6.01 of Rev. Proc. 2025-23), go with this return if it is the timely filed return, including extensions.
The 2027 tax deadlines for a cost segregation study
Source: Instructions for Form 7004
Return or payment due
Extended 2026 individual and C corp returns due
For a calendar-year individual (Form 4868) or C corporation (Form 7004) on extension and not yet filed, the extended 2026 return is due October 15, 2027; the extension was of time to file, not to pay, so tax owed was due in April. For an investor still holding a pre-2027 QOF investment, that extended 2026 return reports the 2026 deferred-gain inclusion with Form 8997.
Depreciation
Placed in service by Dec 31 (calendar-year taxpayers)
For a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31 is first depreciated on that year’s return, and property placed in service on January 1 or later is first depreciated on the next year’s return. A cost segregation study on that property can be completed after year-end, before the return is filed; buying or placing property in service for the deduction alone is not a reason to do either.
Placing property in service by December 31 for cost segregation
Zone map
Puerto Rico’s original Opportunity Zones end
Under Rev. Proc. 2026-14 section 2.02(2)(c), the original Opportunity Zones in Puerto Rico remain designated through December 31, 2027, a year before the other 2018 zones. Puerto Rico tracts designated in the 2026 round run from January 1, 2027.
Fund
QOF 90% asset test: year-end testing date
For a calendar-year qualified opportunity fund, the last day of the tax year, December 31, is one of the two dates whose average must show at least 90% of assets in qualified opportunity zone property (§1400Z-2(d)(1)). The values are reported on Form 8996 with the fund’s return.
Source: IRC §1400Z-2(d)(1)
Return or payment due
2027 partnership and S corporation returns due
For a calendar-year partnership or S corporation, the 2027 return (Form 1065 or 1120-S) is due March 15, 2028, and a QOF taxed as a partnership or S corporation attaches Form 8996 to it; Form 7004 gives an automatic 6-month extension of time to file, not to pay. An automatic accounting-method change on Form 3115 (for example, catch-up depreciation after a cost segregation study on property the partnership or S corporation placed in service in an earlier tax year and still owns, when it meets the conditions in section 6.01 of Rev. Proc. 2025-23) is attached to the timely filed original return for the year of change, including extensions (Rev. Proc. 2015-13 section 6.03(1)(a)).
Source: IRC §6072(b)
Return or payment due
2027 individual and C corporation returns due
For a calendar-year individual or C corporation, the 2027 return is due April 18, 2028, and any tax owed is due that day even with an extension, which is an extension of time to file, not to pay. A QOF investor attaches Form 8997 for any year it held a QOF investment, and a C corporation QOF attaches Form 8996.
Computed under IRC §7503; to be checked against IRS Publication 509 for that year when it is published.
Source: IRC §6072(a) and §7503
Fund
QOF 90% asset test: six-month testing date
For a calendar-year qualified opportunity fund that has been a QOF since the start of its tax year, June 30 is the last day of the first 6-month period and one of the two §1400Z-2(d)(1) testing dates for the 90% asset test. A fund that first became a QOF partway through the year starts its 6-month period in that first month, so its date differs (Form 8996 instructions).
Source: Instructions for Form 8996
Return or payment due
Extended 2027 partnership and S corp returns due
For a calendar-year partnership or S corporation that filed Form 7004, the extended 2027 return is due September 15, 2028; the extension was of time to file, not to pay. A Form 8996 for a QOF taxed as a partnership or S corporation, and any Form 3115 for an automatic change for property the entity placed in service in an earlier tax year and still owns (when it meets the conditions in section 6.01 of Rev. Proc. 2025-23), go with this return if it is the timely filed return, including extensions.
Source: Instructions for Form 7004
Return or payment due
Extended 2027 individual and C corp returns due
For a calendar-year individual (Form 4868) or C corporation (Form 7004) on extension and not yet filed, the extended 2027 return is due October 16, 2028; the extension was of time to file, not to pay, so tax owed was due in April.
Computed under IRC §7503; to be checked against IRS Publication 509 for that year when it is published.
Depreciation
Placed in service by Dec 31 (calendar-year taxpayers)
For a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31 is first depreciated on that year’s return, and property placed in service on January 1 or later is first depreciated on the next year’s return. A cost segregation study on that property can be completed after year-end, before the return is filed; buying or placing property in service for the deduction alone is not a reason to do either.
Placing property in service by December 31 for cost segregation
Zone map
Original 2018 Opportunity Zones end
Under Rev. Proc. 2026-14 section 2.02(2)(c), the Opportunity Zones designated in 2018 (outside Puerto Rico) remain designated through December 31, 2028. A 2018 tract that was also designated in the 2026 round continues as a 2027 zone through December 31, 2036.
Fund
QOF 90% asset test: year-end testing date
For a calendar-year qualified opportunity fund, the last day of the tax year, December 31, is one of the two dates whose average must show at least 90% of assets in qualified opportunity zone property (§1400Z-2(d)(1)). The values are reported on Form 8996 with the fund’s return.
Source: IRC §1400Z-2(d)(1)
Which Opportunity Zone dates are not on a calendar?
- The 180-day window to invest a gain in a Qualified Opportunity Fund runs from the date of the sale or exchange under IRC §1400Z-2(a)(1)(A), so it has no fixed calendar date.
- For amounts invested after December 31, 2026, the five-year inclusion, the basis increase of 10% of the deferred gain after five years (30% for a qualified rural opportunity fund) and the 10-year election under §1400Z-2(c) run from each investor’s own investment date.
- No rule fixes the day Treasury publishes the 2027 Opportunity Zone list; the calendar carries only the outer dates in Rev. Proc. 2026-14.
Frequently Asked Questions
How do you add the Opportunity Zone calendar to Google Calendar or Outlook?
Choose Subscribe in Google Calendar or Subscribe in Outlook on this page: each adds the calendar by its web address, so a corrected or added date reaches the subscribed calendar the next time the app refreshes it, on the app’s own schedule, which can take a day or more. Apple Calendar subscribes through the webcal link, and the downloaded .ics file is a one-time copy that does not update.
What happens to Opportunity Zone deferred gain on December 31, 2026?
For an investor still holding a qualifying QOF investment made on or before December 31, 2026, the remaining deferred gain is included in income for 2026 under Notice 2026-40 section 4.01, unless an earlier inclusion event already triggered it. The amount is the lesser of the deferred gain or the investment’s fair market value on December 31, 2026, minus the investor’s basis in it (§1400Z-2(b)(2)). The investor’s basis in the QOF interest is then increased by the gain recognized (§1400Z-2(b)(2)(B)(ii)), and where the fund is taxed as a partnership, §704(d) allows the investor’s share of partnership losses, including depreciation a cost segregation study accelerates, only up to the investor’s outside basis, which includes that increase and the investor’s share of partnership liabilities under §752.
Does December 31, 2026 decide which Opportunity Zone map a fund’s property is tested against?
For property a fund acquires, the acquisition date decides it: under Notice 2026-40 section 5.01, tangible property a QOF or QOZ business acquires after December 31, 2026 cannot be qualified opportunity zone business property unless it is acquired for use in a zone designated after July 4, 2025 or an exception applies (a working capital safe harbor plan meeting the 2026 thresholds, or ordinary-course replacement property), whatever the date the investor’s money went in. A cost segregation study does not change which map applies; it records the components and costs of the property the fund acquired, with the dates its depreciation schedule needs.
When does property have to be placed in service to be depreciated on this year’s return?
For a calendar-year taxpayer, property placed in service (ready and available for its intended use) by December 31 is first depreciated on that year’s return under Treas. Reg. §1.167(a)-11(e)(1)(i), and property placed in service on January 1 or later is first depreciated on the next year’s return. A cost segregation study on that property can be completed after year-end, before the return is filed, and buying or placing property in service for the deduction alone is not a reason to do either.
Which return carries a cost segregation study for a partnership Qualified Opportunity Fund?
For a calendar-year partnership QOF, it is the partnership return (Form 1065), with Form 8996 attached. For a calendar-year partnership that return is due March 15 (the next business day when that falls on a weekend or legal holiday, IRC §7503), or September 15 under a Form 7004 extension, which is an extension of time to file, not to pay. When the study supports an automatic accounting-method change on Form 3115 for property the partnership placed in service in an earlier tax year and still owns, the form is attached to the timely filed original return for the year of change, including extensions (Rev. Proc. 2015-13 section 6.03(1)(a)), and whether the change is available depends on the conditions in section 6.01 of Rev. Proc. 2025-23.
Why are the 2028 due dates April 18 and October 16?
Under IRC §7503 a due date that falls on a Saturday, Sunday or legal holiday moves to the next business day: April 15, 2028 is a Saturday and Emancipation Day is observed in Washington, D.C. on Monday, April 17, so the calendar-year individual and C corporation return is due April 18, 2028, and October 15, 2028 is a Sunday, so the return on extension is due October 16, 2028. As of October 2026, the IRS had not published its 2028 calendar, so both dates will be checked against IRS Publication 509 for 2028 when it is out and corrected here if they differ.
The Opportunity Zone cost segregation guide explains the zero-basis limit and what happens to depreciation at exit, and the cost segregation qualifier shows whether a study is likely to fit a property.
Open the cost segregation qualifier