Defer the original gain
Defer recognition of eligible gain until the fifth anniversary of your investment, unless an earlier inclusion event occurs.
Opportunity Zone planningYour gain.
Your gain.
Your next opportunity.
Turn a taxable gain into a long-term investment strategy. Explore a self-directed investment or a professionally managed private equity fund—with tax planning, structuring, and coordination built around your goals.
Three potential federal tax benefits
Defer. Reduce. Grow.
For eligible investments in a Qualified Opportunity Fund (QOF) made on or after January 1, 2027.
Exclude part of that gain
After five years, a basis increase generally excludes 10% of the deferred gain—or 30% for an investment in a qualified rural opportunity fund.
Tax-free eligible appreciation
After at least ten years, an election can eliminate federal income tax on eligible QOF investment appreciation at exit. For holdings beyond 30 years, the basis adjustment uses the investment’s value at year 30.
The investment date matters. Investments made through December 31, 2026 follow the original program’s rules, including its December 31, 2026 deferred-gain inclusion date. The exit benefit does not erase the original deferred gain or exempt ongoing operating income. State treatment, eligibility, elections, and transaction structure require separate review.
Where eligible gains can come from
More than a real estate strategy.
Potential sources include taxable capital gains and eligible Section 1231 gains from transactions such as:
- Sale of stockPublicly traded shares or privately held stock.
- Sale of a primary homeTaxable gain above the available $250,000 exclusion, or $500,000 for eligible married couples filing jointly.
- Sale of a vacation propertyTaxable gain from a second home.
- Sale of a businessEligible gain from an equity or asset sale; ordinary-income components require separate treatment.
- Sale of real estateEligible gain from investment or business property.
- Boot from a 1031 exchangeThe eligible taxable gain recognized when cash or other non-like-kind property is received.
- A failed 1031 exchangeA potential alternative for eligible gain when an exchange cannot be completed and the QOF investment deadline remains available.
Generally, eligible gain must be invested within 180 days, with special timing rules for some transactions and pass-through entities. A failed exchange does not automatically restart that clock. Review timing before funds are released; ordinary income and related-party gains generally do not qualify.
Track 01 / Self-directedMore control.
More control.
A coordinated plan.
Build your own QOF and investment structure around a property or business opportunity. Match the execution demands to your experience, liquidity, and long-term goals.
Original use
Acquire qualifying newly completed property before its first placement in service in the zone. This can avoid taking on ground-up development yourself. Pre-leasing or an appropriately structured tenant commitment may also reduce—and in some cases largely avoid—initial lease-up exposure.
Original use is a tax qualification test, not a risk rating. Prior use, placement-in-service timing, tenant arrangements, and any vacancy exception must be verified. An already occupied property does not qualify simply because it is new to you.
Substantial improvement
Reposition or renovate an existing property under a qualifying improvement plan. A successful transformation may offer a higher growth rate, alongside greater construction, budget, timing, financing, and leasing risk.
The required investment must satisfy the applicable improvement threshold within the 30-month period. Rural projects may qualify for a reduced threshold. Project economics and execution capacity should drive the decision.
From structure to ongoing reporting
- Structuring: QOF and Qualified Opportunity Zone Business (QOZB) design, ownership, funding, and investment timing.
- Compliance: Qualification review, asset tests, working capital planning where applicable, and milestone tracking.
- Reporting: Coordinate fund and investor reporting, elections, and tax-return information with your preparers.
- Team coordination: Legal, brokerage, financing, development, estate planning, accounting, tax preparation, and operations.
Track 02 / Private equity fundsSponsor-led execution.
Sponsor-led execution.
Planning that stays personal.
A fund can put investment execution in a sponsor’s hands. We help investors and sponsors connect the structure, economics, and reporting to the intended tax outcome.
Evaluate the investment in your broader plan.
- Self-directed QOF structuring, compliance, and coordination where the sponsor’s structure supports investment into an eligible underlying QOZB.
- Sponsor and deal tax and business underwriting as part of individual tax planning: review assumptions, leverage, fees, distributions, exit scenarios, and after-tax outcomes.
- Coordinate investment timing, reporting, liquidity needs, and estate planning with your existing advisors.
Build a clear, supportable offering.
- Deal modeling and structuring, including capital needs, distributions, tax outcomes, and exit scenarios.
- Assistance with offering memorandum tax and financial content, coordinated with securities and other legal counsel.
- Investor education and reporting, compliance planning, and ongoing qualification monitoring.
- Coordination across legal, brokerage, financing, development, estate planning, accounting, tax preparation, and operations.
Real estate brokerageConnect the plan
Connect the plan
to the property.
For real estate acquisition and disposition services, connect with Max Unger through Institutional Property Advisors, a division of Marcus & Millichap.
Explore STRCREBrokerage services are provided through the brokerage under a separate engagement.
Thought Leadership
Explore the framework.
Our Opportunity Zone White Paper discusses program benefits, qualification, investment strategies, estate planning, and state considerations.
Read the whitepaperResearch & reference links
The whitepaper is dated January 2026. Confirm current guidance and zone eligibility before acting.
Tax references
IRC §1400Z-2, including the 2027 amendments · IRS Notice 2026-40: transition guidance · IRS Opportunity Zone FAQs · IRS: sale of your home
Federal overview as of September 2026. Benefits depend on the investment date, qualifying gain, holding period, fund and property compliance, and required elections. Investment risk and state taxes remain relevant.
Let’s start with your situation
Start a conversationYour next decision deserves a plan.
Tell us what you’re considering, what’s at stake, and when you need to act.