Qualified Opportunity Zone (QOZ) Tax Deferral Calculator 2026
Estimate the tax deferral, basis step-up, and post-2026 tax-free appreciation on a Qualified Opportunity Fund (QOF) investment under IRC § 1400Z-2. Compare 5-, 7-, and 10-year holding periods, the December 31, 2026 inclusion event, and the FMV step-up at 10+ years. Free, private, runs entirely in your browser. The original TCJA QOZ program is scheduled to sunset — verify current law (One Big Beautiful Bill Act 2025) before relying on these numbers.
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Source: IRC § 1400Z-2 (Cornell LII) + IRS Opportunity Zones FAQ + IRS Form 8997. Last updated: May 3, 2026.
What Is a Qualified Opportunity Zone (QOZ)?
A Qualified Opportunity Zone (QOZ) is an economically distressed census tract designated by the U.S. Treasury under IRC § 1400Z-1, originally enacted by the Tax Cuts and Jobs Act of 2017. By rolling an eligible capital gain into a Qualified Opportunity Fund (QOF) within 180 days of recognition, an investor can defer federal tax on that gain until December 31, 2026 (or until the QOF is sold, whichever comes first). Long-term holders earn additional tax benefits: a basis step-up after 5 and 7 years (pre-2022 investments only), and after 10 years a full step-up to fair market value, making post-investment appreciation effectively tax-free at the federal level. Source: IRS Opportunity Zones FAQ + IRC § 1400Z-2.
The Three QOZ Tax Benefits — How Each Tier Works
The QOZ program layers three distinct federal tax benefits, each tied to how long the investor holds the QOF interest:
- Tier 1 — Deferral (always available): The original capital gain is excluded from gross income in the year recognized and is instead reported on December 31, 2026, or the date the QOF interest is sold — whichever comes first. This is a deferral, not forgiveness; the deferred gain still gets taxed.
- Tier 2 — Basis step-up (largely expired): Investors who held a QOF for 5 years got a 10% basis step-up; 7 years got 15%. Because the deferral inclusion date is fixed at 12/31/2026, only investments made by 12/31/2021 (5-year) or 12/31/2019 (7-year) qualified. New investments in 2026 cannot earn these step-ups under the original TCJA law.
- Tier 3 — 10-year FMV step-up (still available): If the QOF interest is held at least 10 years, the investor can elect to step the basis up to fair market value on sale, eliminating federal tax on all post-investment appreciation. This benefit remains available for 2026 investments under the existing statute.
The 12/31/2026 Inclusion Event — What Happens This Year
Every QOF investor who deferred gains under the original TCJA program faces the same inclusion event on December 31, 2026: the deferred gain is recognized on that date, taxed at the federal long-term capital gains rate then in effect (currently 0%, 15%, or 20% based on income), plus 3.8% NIIT for high earners and any state CGT. Investors must file IRS Form 8997 to track their QOF interests and Form 8949 to report the inclusion. The taxable amount is the deferred gain minus any basis step-up earned (10% or 15% if applicable, otherwise zero). The One Big Beautiful Bill Act of 2025 may extend or modify this inclusion date — taxpayers should verify the current statutory deadline with their CPA or read the most recent IRS guidance before filing.
QOZ vs. Pay-Now Comparison: When the Deferral Pays Off
The QOZ trade is straightforward: defer paying tax on the original gain by 7-10 years, invest the full pretax amount, and earn tax-free appreciation if you hold 10+ years. The break-even depends on three things — the original gain rate, the QOF growth rate, and the time horizon. At 8% projected QOF growth and a 23.8% blended federal rate (20% LTCG + 3.8% NIIT), the 10-year FMV step-up alone typically beats paying tax now and investing in a taxable brokerage account by 15-30%. The calculator above runs this comparison live with your inputs. Note: the 5- and 7-year basis step-ups are now mostly historical for new 2026 investments under the original statute — the 10-year FMV step-up is the dominant remaining benefit. Verify the program's status under the OBBB Act 2025 and any post-2026 extensions before committing capital. Last updated: May 3, 2026.