ACTEC 2026 Annual Meeting

Kevin will present “Qualified Opportunity Zone Fund Planning in 2026 in Light of the OBBBA,” focusing on key tax and estate planning issues affecting Qualified Opportunity Zone (QOZ) and Qualified Opportunity Fund (QOF) investments.

His presentation will cover the core tax benefits and requirements of QOF investing, including gain deferral, basis adjustments, and long‑term gain exclusion, as well as important estate planning considerations, many of which remain unchanged under the OBBBA. Topics will include the treatment of QOF interests at death, planning with gifts and grantor trusts, and holding period considerations for heirs.  Special attention will be devoted to the deferred gain recognition date of December 31, 2026 under the first tranche of QOZ rules ushered in under the Tax Cuts and Jobs Act of 2017, and the nuances that apply in determining the amount of the deferred gain, taking into account, if lower, the fair market value of the pro rata fund interest at that time.

The program will also address pass‑through entity rules and major changes under the OBBBA, including rolling gain deferral, a permanent 10% basis step‑up, stricter Opportunity Zone eligibility standards, the introduction of Qualified Rural Opportunity Funds, and new reporting requirements.

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