News & Insights

IRS Proposes Transitional QOZ Guidance

  • August 27, 2026
  • Publications

In their latest New York Law Journal column, Roberts & Holland partners Ezra Dyckman and Aaron Gaynor examine IRS Notice 2026-40, which provides safe harbors designed to preserve existing qualifying investments and permit new qualifying investments in existing QOZs even after those zones’ designations expire.

While the notice is currently a proposed framework for future regulations and taxpayers technically cannot rely on it, the guidance signals important planning considerations. As Ezra and Aaron explain, taxpayers may wish to evaluate potential actions before the end of 2026.

“Taxpayers may want to take action before the end of 2026.”

Read their article here.