Representative · D-FL
The bill extends and clarifies Opportunity Fund incentives and adds tenant protections to steer private investment toward affordable housing, trading off near-term federal revenue, increased administrative burdens, and potential financing challenges that could slow some housing production.
Taxpayers/investors can defer capital gains and access Qualified Opportunity Fund benefits through 2036, extending tax incentives that encourage investment in distressed communities.
Low-income residents (≤100% AMI) in qualified projects gain access to targeted affordable units when the 30% occupancy test is met, increasing housing options for those households.
Renters gain short-term stability and predictability from a 3% annual rent cap and a 60-day notice requirement for rent increases.
Extending tax-preference windows will reduce near-term federal revenue, increasing budget pressures and potentially crowding out other priorities.
Rent caps and income-based occupancy rules could limit market-rate units and complicate financing for mixed-income projects, potentially slowing housing production.
Stricter occupancy rules and rent caps may make some QOF residential projects less financially attractive, reducing investor interest and private capital flowing into some zones.
Based on analysis of 1 section of legislative text.
Extends Opportunity Zone timing and elections to 2036, adjusts basis rules, and adds occupancy, rent-cap, and notice requirements for qualifying residential projects.
Official title: To amend the Internal Revenue Code of 1986 to modify the rules for investments in qualified opportunity funds, and for other purposes.
Introduced March 5, 2026 by Sheila Cherfilus-McCormick · Last progress March 5, 2026
Extends and changes rules for investments in Qualified Opportunity Funds (QOFs). It lengthens several timing deadlines for opportunity zone designations and elections, creates different deadlines for investments made before versus after the law, adjusts rules that determine basis increases, and adds new tenant- and rent-related tests for when residential rental projects qualify as Opportunity Zone property. Most changes take effect on enactment; the longer designation period applies to zones already in effect on that date.