The 30-year limit on Opportunity Zone gains

It is a cap on the 10-year exclusion: for a Qualified Opportunity Fund (QOF) investment sold after its 30th anniversary, basis is set at fair market value on the 30th anniversary instead of on the date of sale.^1,2

The exclusion works by resetting basis to fair market value. If you have held a QOF investment at least 10 years, you can elect on sale to treat your basis as its value, so the appreciation is not taxed.³ Under §1400Z-2(c) as amended by Public Law 119-21, that reset is measured no later than the 30th anniversary of the investment.^4,5 Value added after that date is taxed when you sell, as ordinary appreciation would be.

It applies to amounts invested in QOFs after December 31, 2026, the same investments that receive the rolling five-year deferral and the 10% or 30% step-up.^6,7

Each investment has its own 30-year date, measured from the date that investment was made. Investors who fund in several tranches will have several anniversaries. The limit applies equally to standard QOFs and to Qualified Rural Opportunity Funds; the rural fund's advantage is in the year-5 step-up, not the exclusion.⁴

Selling at or before the 30th anniversary excludes all appreciation; selling five years later taxes the value added in those five years.

Assumptions: $1,000,000 of long-term gain invested March 15, 2027 in a standard QOF; basis $1,000,000 after the year-5 inclusion; investment value $10,000,000 at year 30, $13,000,000 at year 35 and $16,000,000 at year 40; post-year-30 appreciation is long-term capital gain taxed at 23.8% federal (20% plus 3.8% net investment income tax); no state tax; current rates throughout. Figures are illustrative.

No. The 30-year rule fixes the basis used on a later sale; it does not by itself require a sale or trigger tax at year 30, as described in practitioner summaries of the amended statute.^2,4

Holding past year 30 can still make sense. You keep the excluded value locked in, and tax on later growth is deferred until you sell, like any other investment. The cost is that you need evidence of the year-30 value years or decades later, which is where the open questions are. Family offices with multigenerational horizons should plan the year-30 date as carefully as the year-10 date. See Opportunity Zones for family offices.

The planning goal is simple: realize as much appreciation as possible on or before the 30th anniversary, or accept that later growth will be taxed like any other investment.³

Because a fund-level asset sale can qualify for the election, a sponsor can also schedule dispositions of individual properties before investors' 30-year dates, which is useful in multi-asset funds with investors who came in at different times.⁸ See single-asset vs. multi-asset funds.

How the year-30 fair market value is determined, documented and elected when there is no sale at year 30 is unsettled, and Treasury has asked for comments.^9,10

Notice 2026-55, released September 22, 2026, requests comments on several §1400Z-2 issues, including the year-30 election and valuation; comments are due November 23, 2026.⁹ Until regulations are proposed, these questions are open:

• Valuation method. Whether an appraisal at the anniversary will be required, and what standard (for example, enterprise value of a QOF partnership interest versus the fund's underlying assets) applies.
• Timing of the election. Whether the investor must elect or report anything in the year of the 30th anniversary, or only on the later sale.
• Partnership mechanics. How a QOF partnership will adjust inside basis or report year-30 values to investors so a later asset sale can be measured.
• Interaction with inclusion events and transfers after year 30, including gifts and transfers at death.

It is the last of four time-based markers: 180 days to invest, five years to the step-up and inclusion, 10 years to the exclusion, and 30 years to the cap.⁵

For most funds, the 30-year cap is far from the planned exit; many sponsors target a sale between years 10 and 15. It matters most for long-lived infrastructure and for investors who want to own an asset indefinitely. See the 180-day rule, the five-year deferral, the 10-year hold and key dates and timeline.

It can, because powered land, substations, shells and cooling plants can stay productive for decades, while servers and other IT equipment turn over on cycles of five or six years.¹¹

A data center fund that plans to hold a campus long term should treat year 30 as a natural exit or recapitalization date, and should expect several equipment and tenant cycles before it. Sponsors also need to keep the QOZB actively operating the facility for the whole holding period, since merely entering into a triple-net lease is not an active trade or business under the regulations, and the exclusion depends on the fund and its business continuing to qualify.¹² See how a data center Opportunity Zone fund works.