Information Reporting Regarding Qualified Opportunity Zones and Updated Qualified Opportunity Fund Certification and Decertification Procedures; Correction

Issuing agencies

Abstract

This document contains corrections to the proposed regulations (REG-116506-25), published in the Federal Register on September 11, 2026. These proposed regulations would implement new statutory requirements for qualified opportunity funds to file information returns with the IRS and furnish statements to investors who dispose of investments in those entities and for qualified opportunity zone businesses to furnish statements to qualified opportunity funds that hold interests in them.

Full Text

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<title>Federal Register, Volume 91 Issue 216 (Tuesday, November 10, 2026)</title>
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[Federal Register Volume 91, Number 216 (Tuesday, November 10, 2026)]
[Proposed Rules]
[Pages 72493-72495]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-22859]


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DEPARTMENT OF THE TREASURY

Internal Revenue Service

26 CFR Parts 1 and 301

[REG-116506-25]
RIN 1545-BR82


Information Reporting Regarding Qualified Opportunity Zones and 
Updated Qualified Opportunity Fund Certification and Decertification 
Procedures; Correction

AGENCY: Internal Revenue Service (IRS), Treasury.

ACTION: Notice of proposed rulemaking and notice of public hearing; 
correction.

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SUMMARY: This document contains corrections to the proposed regulations 
(REG-116506-25), published in the Federal Register on September 11, 
2026. These proposed regulations would implement new statutory 
requirements for qualified opportunity funds to file information 
returns with the IRS and furnish statements to investors who dispose of 
investments in those entities and for qualified opportunity zone 
businesses to furnish statements to qualified opportunity funds that 
hold interests in them.

DATES: The deadline for submitting written or electronic comments on 
the proposed rule was October 26, 2026.

ADDRESSES: Commenters are strongly encouraged to submit public comments 
electronically. Submit electronic submissions via the Federal 
eRulemaking Portal at <a href="https://www.regulations.gov">https://www.regulations.gov</a> (indicate IRS and 
REG-116506-25) by following the online instructions for submitting 
comments. The public hearing will be conducted by telephone only. Once 
submitted to the Federal eRulemaking Portal, comments cannot be edited 
or withdrawn. The Department of the Treasury (Treasury Department) and 
the IRS will publish any comments submitted electronically or on paper 
to the public docket. Send paper submissions to: CC:PA:01:PR (REG-
116506-25), Room 5503, Internal Revenue Service, P.O. Box 7604, Ben 
Franklin Station, Washington, DC 20044.

FOR FURTHER INFORMATION CONTACT: Concerning the proposed regulations 
under section 1400Z-2, Dominic DiMattia of the Office of the Associate 
Chief Counsel (Income Tax and Accounting) at (202) 317-7009 (not a 
toll-free number); concerning the remainder of the proposed regulations 
under sections 6011, 6037, 6039K, 6039L, 6045, 6722, 6724, and 6726, 
Roseann Cutrone of the Office of the Associate Chief Counsel (Procedure 
and Administration) at (202) 317-6844 (not a toll-free number); and 
concerning submissions of comments or the public hearing, the 
Publications and Regulations Section at (202) 317-6901 (not a toll-free 
number) or by sending an email to <a href="/cdn-cgi/l/email-protection#0a7a7f68666369626f6b7863646d794a637879246d657c"><span class="__cf_email__" data-cfemail="a5d5d0c7c9ccc6cdc0c4d7cccbc2d6e5ccd7d68bc2cad3">[email&#160;protected]</span></a> (preferred).

SUPPLEMENTARY INFORMATION:

Background

    The proposed regulations (REG-116506-25) subject to this correction 
contain proposed amendments to the Income Tax Regulations (26 CFR part 
1) that would revise existing regulations under sections 1400Z-2 and 
6045 of the

[[Page 72494]]

Internal Revenue Code (Code) and add new regulations under sections 
6039K and 6039L of the Code. These proposed regulations also contain 
proposed amendments to the Procedure and Administration Regulations (26 
CFR part 301) that would revise existing regulations under sections 
6011, 6037, 6722, and 6724 of the Code and add new regulations under 
section 6726 of the Code.

Correction of Publication

    Accordingly, FR Doc. 2026-18574 (REG-116506-25), appearing on page 
57968 in the Federal Register on September 11, 2026, is corrected as 
follows:
    1. On page 57970, in the second column, in the first partial 
paragraph, in the third line from the bottom of the paragraph, the word 
``nonqualified'' is corrected to read ``non-qualified''.
    2. On page 57971, in the second column, in the third full 
paragraph, in the second line from the bottom of the paragraph, the 
word ``enactments'' is corrected to read ``enactment''.
    3. On page 57971, in the third column, in the first full paragraph, 
in the fifth line from the bottom of the paragraph, the language ``QOFs 
taxable year'' is corrected to read ``QOF's taxable year''.
    4. On page 57971, in the third column, in the second full 
paragraph, in the second line from the top of the paragraph, the 
language ``investments standards'' is corrected to read ``investment 
standards''.
    5. On page 57971, in the third column, in the third full paragraph, 
in the third line from the top of the paragraph, the language 
``businesses property'' is corrected to read ``business property''.
    6. On page 57972, in the first column, in the first full paragraph, 
in the fourth line from the bottom of the paragraph, the language 
``disposed of'' is corrected to read ``disposed-of''.
    7. On page 57975, in the first column, in the last partial 
paragraph, in the eighth line from the bottom of the page, the language 
``III.B.3. and B.4.'' is corrected to read ``II.B.3. and B.4.''.
    8. On page 57976, in the second column, in the first partial 
paragraph, in the twenty third line from the top of the page, the 
language ``III.B.1. through 3.'' is corrected to read II.B.1. through 
3.''.
    9. On page 57976, in the second column, in the first partial 
paragraph, in the seventh line from the bottom of the paragraph, the 
language ``Sec.  1.6039K-1(j)(1)'' is corrected to read ``Sec.  
1.6039K-1(i)(1)''.
    10. On page 57976, in the second column, in the last partial 
paragraph, in the fifth line from the bottom of the page, the word 
``though'' is corrected to read ``through''.
    11. On page 57976, in the third column, in the first partial 
paragraph, in the seventh line from the bottom of the paragraph, the 
language ``Sec.  1.6039K-1(j)(2)'' is corrected to read ``Sec.  
1.6039K-1(i)(2)''.
    12. On page 57976, in the third column, in the first full 
paragraph, in the first line of the paragraph, the language ``Sec.  
1.6039K-1(k)'' is corrected to read ``Sec.  1.6039K-1(j)''.
    13. On page 57976, in the third column, in the second full 
paragraph, in the fifth line from the bottom of the paragraph, the 
language ``parts III.B.2. and III.B.3.a.'' is corrected to read ``parts 
II.B.2. and II.B.3.a.''.
    14. On page 57977, in the second column, in the first full 
paragraph, the fourth line from the top of the page is corrected to 
read ``in section 6039K. Section 6039K(d)(2)''.
    15. On page 57977, in the second column, in the first full 
paragraph, the seventh line from the top of the page is corrected to 
read ``of: (A) the number of full-time employees''.
    16. On page 57978, in the second column, in the last partial 
paragraph, in the fourth line from the top of the paragraph, the 
language ``QOFs compliance'' is corrected to read ``QOF's compliance''.
    17. On page 57978, in the third column, in the last partial 
paragraph, in the fifth line from the bottom of the page, the language 
``part IV.A.'' is corrected to read ``part III.A.''.
    18. On page 57979, in the first column, in the second full 
paragraph, the fourth line from the top of the paragraph is corrected 
to read ``are currently required to report on''.
    19. On page 57979, in the first column, in the last partial 
paragraph, in the tenth line from the bottom of the page, the language 
``part IV.B.1'' is corrected to read ``part III.B.1''.
    20. On page 57979, in the second column, in the second full 
paragraph, in the nineth line from the bottom of the paragraph, the 
word ``dates'' is removed.
    21. On page 57981, in the third column, in the first full 
paragraph, in the fifth line from the bottom of the paragraph, the 
language ``part VIII'' is corrected to read ``part VII''.
    22. On page 57982, in the third column, in the last partial 
paragraph, in the seventeenth line from the top of the paragraph, the 
word ``in'' is removed.
    23. On page 57983, in the first column, in the first full 
paragraph, in the fifth line from the top of the paragraph, the 
language ``investment statements'' is corrected to read ``investor 
statements''.
    24. On page 57983, in the third column, in the first full 
paragraph, in the third line from the top of the paragraph, the word 
``every'' is removed.
    25. On page 57983, in the third column, in the last partial 
paragraph, in the eighth line from the top of the paragraph, the word 
``though'' is corrected to read ``through''.
    26. On page 57983, in the third column, in the last partial 
paragraph, in the nineth line from the top of the paragraph, the 
language ``parts IV.B.1. through 3.'' is corrected to read ``parts 
III.B.1. through 3.''.
    27. On page 57983, in the third column, in the last partial 
paragraph, in the last line of the page, the language ``part IV.C.'' is 
corrected to read ``part III.C.''.
    28. On page 57984, in the first column, in the first partial 
paragraph, in the second line from the top of the page, the language 
``Sec.  1.6039L-1(d)'' is corrected to read ``Sec.  1.6039L-1(e)''.
    29. On page 57984, in the first column, in the first partial 
paragraph, in the eighth line from the top of the page, the language 
``Sec.  1.6039L-1(d)'' is corrected to read ``Sec.  1.6039L-1(f)''.
    30. On page 57984, in the first column, in the first full 
paragraph, in the first line of the paragraph, the language ``part 
IV.A.'' is corrected to read ``part III.A.''.
    31. On page 57984, in the first column, in the first full 
paragraph, the eighth line from the top of the paragraph, the word 
``though'' is corrected to read ``through''.
    32. On page 57984, in the second column, in the last partial 
paragraph, in the nineth line from the bottom of the page, the language 
``in its taxable year'' is corrected to read ``during their taxable 
years''.
    33. On page 57985, in the third column, in the first full 
paragraph, the third line from the bottom of the paragraph is corrected 
to read ``investments are compliant with section''.
    34. On page 57986, in the first column, in the last partial 
paragraph, in the fourth line from the top of the paragraph, the 
language ``section 1400Z2-2(d)(3)'' is corrected to read ``section 
1400Z-2(d)(3)''.
    35. On page 57986, in the second column, in the first full 
paragraph, in the sixth line from the top of the paragraph, the word 
``used'' is removed.
    36. On page 57986, in the second column, in the second full 
paragraph, in the fourth line from the top of the

[[Page 72495]]

paragraph, the language ``part IV.B.1.'' is corrected to read ``part 
III.B.1.''.
    37. On page 57986, in the second column, in the last partial 
paragraph, in the third line from the bottom of the page, the language 
``relevant QOFs'' is corrected to read ``relevant QOF's''.
    38. On page 57987, in the first column, in the last partial 
paragraph, in the first line of the paragraph, the language ``parts 
III.B.3.a.'' is corrected to read '' parts II.B.3.a.''.
    39. On page 57987, in the third column, in the second full 
paragraph, in the seventh line from the bottom of the paragraph, the 
word ``on'' is corrected to read ``in''.
    40. On page 57989, in the second column, in the second full 
paragraph, the sixth line from the top of the paragraph is corrected to 
read ``obligations to the IRS regarding whether 90''.
    41. On page 57989, in the third column, in the first full 
paragraph, in the last line of the paragraph, the word ``the'' is 
removed.
    42. On page 57991, in the second column, correct amendatory 
instruction 2 for Sec.  1.1400Z2-0 and the accompanying regulatory text 
to read as follows:

0
Par. 2. Section 1.1400Z2-0 is amended by:
0
1. Adding an entry for Sec.  1.1400Z2(b)-1(j)(3);
0
2. Revising the entries for Sec.  1.1400Z2(d)-1(a)(2) and (3);
0
3. Adding an entry for Sec.  1.1400Z2(d)-1(e)(3); and
0
4. Revising the entry for Sec.  1.1400Z2(d)-2(d)(3).
    The additions and revisions read as follows:


Sec.  1.400Z2-0  Table of Contents.

* * * * *
    Sec.  1.1400Z2(b)-1 Inclusion of gains that have been deferred 
under section 1400Z-2(a).
* * * * *
    (j) * * *
    (3) Paragraph (c)(15) of this section.
* * * * *
    Sec.  1.1400Z2(d)-1 Qualified opportunity funds and qualified 
opportunity zone businesses.
    (a) * * *
    (2) Required self-certification of an eligible entity as a QOF.
    (3) Voluntary decertification of a QOF.
* * * * *
    (e) * * *
    (3) Applicability date.
    Sec.  1.1400Z2(d)-2 Qualified opportunity zone business property.
* * * * *
    (d) * * *
    (3) Substantially all of a QOF's or qualified opportunity zone 
business's holding period for owned or leased tangible property.
* * * * *


Sec.  1.1400Z2(d)-1  [Corrected]

0
43. On page 57992, in the third column, paragraph (a)(3)(v)(B) is 
corrected to read ``The QOF will continue to be subject to the 
requirements of section 1400Z-2 and the section 1400Z-2 regulations, as 
defined in Sec.  1.1400Z2(a)-1(b)(41).''
0
44. On page 57993, in the first column, in paragraph (a)(3)(vii)(A)(1), 
the third sentence is corrected to read ``Q properly self-certified as 
a QOF as of February 1, 2027, and has thereafter complied with section 
1400Z-2 and the section 1400Z-2 regulations, as defined in Sec.  
1.1400Z2(a-1(b)(41).''
0
45. On page 57993, in the second column, in paragraph 
(a)(3)(vii)(A)(2), in the fourteenth line from the bottom of the 
paragraph the word ``date'' is removed.


Sec.  1.6039K-1   [Corrected]

0
46. On page 57994, in the third column, in paragraph (a)(13), in the 
first sentence, the second occurrence of the language ``for use'' is 
corrected to read ``or''.
0
47. On page 57995, in the first column, in paragraph (c)(5), the 
language ``90-percent'' is corrected to read '' the 90-percent''.
0
48. On page 57995, in the first column, in paragraph (c)(7), in the 
third line from the top of the paragraph, the word ``is'' is removed.
0
49. On page 57995, in the second column, in paragraph (d)(2), the first 
line of the paragraph is corrected to read ``The percent of equity''.
0
50. On page 57996, in the second column, in paragraph (h)(2)(ii), in 
the fifth line from the top of the paragraph, the language ``paragraph 
(a)(14)(i)'' is corrected to read ``paragraph (a)(12)(i)''.
0
51. On page 57996, in the second column, the heading of paragraph 
(h)(3) is corrected to read ``Manner of furnishing investor statements 
to reportable investors--``.
0
52. On page 57996, in the third column, in paragraph (h)(3)(ii)(B), in 
the seventh line from the bottom of the paragraph, the word 
``positing'' is corrected to read ``posting''.
0
53. On page 57996, in the third column, in paragraph (i)(2), in the 
third line from the top of the paragraph, the language ``Sec.  
301.6722'' is corrected to read ``Sec.  301.6722-1''.


Sec.  1.6039L-1   [Corrected]

0
54. On page 57998, in the first column, in paragraph (e), in the third 
line from the top of the paragraph, the language ``See Sec.  301.6722'' 
is corrected to read ``See Sec.  301.6722-1''.


Sec.  301.6724-1  [Corrected]

0
55. On page 57999, in the second column, in paragraph (g)(1)(i)(D), the 
language Sec.  ``1.6039K(a)-1'' is corrected to read ``Sec.  1.6039K-
1(a)''.
0
56. On page 57999, in the second column, in paragraph (j)(4), the last 
line of the paragraph is corrected to read ``6039K(a).''


Sec.  301.6726-1  [Corrected]

0
57. On page 57999, in the third column, in paragraph (a)(4), the fourth 
line from the bottom of the paragraph is corrected to read ``which the 
person required to file a section''.

Oluwafunmilayo A. Taylor,
Chief, Publications and Regulations Section, Associate Chief Counsel, 
(Procedure and Administration).
[FR Doc. 2026-22859 Filed 11-9-26; 8:45 am]
BILLING CODE 4831-GV-P


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