How to Bridge OZ 1.0 Projects to OZ 2.0

In this Masterclass, Jim Lang of Greenberg Traurig will break down how sponsors and investors can position existing OZ 1.0 projects to capture OZ 2.0 benefits, walking through the requirements of IRS Notice 2026-40 and the year-end deadlines that determine which projects make the transition.

What’s covered:

• Overview of the OZ 1.0 to OZ 2.0 transition and why year-end 2026 is the critical window
• Breaking down IRS Notice 2026-40, including Section 5’s deal identification and written working capital safe harbor plan requirements
• Meeting the 10% working capital funding and 5% QOZB property deployment thresholds before December 31, 2026
• How QOZB property in tracts that lose designation can continue to qualify going forward
• Raising new OZ equity after 12/31/2026 and how timely rolled-over gains capture OZ 2.0 benefits