Any investment made prior to 12/31/2027 is under the old rules. The deferral is only until 12/31/2026. If held 10 or more, upon sale you get a step up in basis when sold if the sale date was prior to 12/31/2047. If sold after 12/31/2047, the basis is the basis on 12/31/2047. For investments made after 12/32/2026, there is a tax deferral of the investment and recapture is 5 years after the investment. The recapture is 90% of investment. If the investment is held 10 years or more and the investment is sold prior to holding for 30 years, the basis steps up to market value on date of sale. If the investment is sold more than 30 years after the investment. The step up in basis is the basis after holding for 30 years.