Prop. Treas. Reg. § 1.1400Z2(b)-1 Inclusion of gains that have been deferred under section 1400Z-2(a).

Proposed 2026-09-11 · REG-115420-18 · 91 FR 57968 · Interprets § 1400Z-2 · Would amend § 1.1400Z2(b)-1

Par. 3. Section 1.1400Z2(b)-1 is amended by revising paragraph (c)(15) and adding paragraph (j)(3) to read as follows:

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(c) * * *

(15) Decertification of a QOF. The decertification of a QOF, whether a voluntary decertification pursuant to § 1.1400Z2(d)-1(a)(3) or an involuntary decertification, is an inclusion event.

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(j) * * *

(3) Paragraph (c)(15) of this section. The rules of paragraph (c)(15) of this section apply to taxable years ending on or after [date of publication of final regulations in the Federal Register ].