Your first question is, “What happens with my investments when the Opportunity Zone program expires on Dec. 31, 2047?” Under current law, if you have not disposed of your interest in a QOF by Dec. 31, 2047, you will not be eligible for the basis step-up at the time you do dispose of the QOF. However, since the entity will no longer be a QOF, I would argue that it will be eligible for a step-up in basis at the time of the owner’s death. They did consider user comments which suggested either allowing for a step up based on valuation or removing the time restriction, but determined that the first suggestion would be too subjective to allow and enforce and the second suggestion would be too onerous to administer. Your second question is, “How will the expiration of the Opportunity Zones designation impact existing investments?” The expiration of Opportunity Zone designations on Dec. 31, 2028 will not impact pre-existing investments in QOFs. Your third question is “I have also heard that QOF investments can only be made before Jan. 1, 2027. Why?" Incorrect. The latest gain subject to deferral would be on Dec. 31, 2026. As such, the last day of the 180-day period for investing that gain would be in late June 2027. Why? Because those are the dates set forth in the Internal Revenue Code and the regulations thereunder.