Place-Based Investing After Opportunity Zones: The 2026 Playbook for Long-Hold, Policy-Backed Deals

Place-based investing has matured. Early Opportunity Zone (OZ) enthusiasm sometimes chased the wrong thing—headline tax benefits rather than durable district economics. By 2026, the market will be more disciplined. Investors want long-hold cash flows, infrastructure adjacency, and political durability. And importantly, several OZ-related timelines are now front and center in underwriting.

The IRS’ Opportunity Zones FAQ notes that the deferral of eligible gain lasts until the earlier of an inclusion event or December 31, 2026.  That date is not just a tax detail; it’s a planning anchor. It affects fundraising cycles, asset sales timing, and whether sponsors prioritize stabilization or repositioning.

At the same time, policy discussion has increasingly focused on what comes next. Brookings described a reform path in which the current set of zones would sunset at the end of 2026 and a new set would begin in January 2027 (with different eligibility rules and

timelines).  Separately, coverage of 2025 legislative changes has emphasized a transition period before old rules sunset at year-end 2026, highlighting the strategic importance of timing and designation changes. The precise details can be complex and evolve, but the practical takeaway for 2026 underwriting is straightforward: timing matters again.