The code provides that capital gains recognized through Dec. 31, 2026, are eligible to be invested in a QOF. Such gains would have to be timely invested in a within 180 days. So the last day a timely investment in a QOF could be made would be June 28, 2027. As you know, if a qualifying QOF investor holds its QOF interest for at least five years on or before Dec. 31, 2026, 10% of its roll-over gain is eliminated and if a qualifying QOF investor holds its interest for at least seven years on or before Dec. 31, 2026, another 5% of its roll-over gain (for a total of 15%) is eliminated. On Dec. 31, 2026, depending on how long the qualifying QOF investor held its QOF interest, it must recognize 100%, 90% or 85% of its roll-over gain. Any investment after 2019 is not eligible for the seven-year benefit and any investment after 2021 is not eligible for the seven-year or five-year benefits. The other benefit to QOZ investors is if a qualifying QOF investor holds interest in the QOF for at least 10 years and then it sells QOF interest, or the QOF sells its property and the QOF investor does not recognize any additional gain.