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What is the timeline for when the 180-day rule kicks in when it comes to an Opportunity Zone transaction?

I recognized capital gains from the sale of my OZ property but it's not a one-off payment but will be paid to me over installments. In this case, what is the date at which the 180-day rule starts for excluding gains from taxes? The date of the first installment or the last?


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  • Matthew Rappaport
    April 11, 2023

    Each installment has a separate timer, and it's an elective timer: it could start on either the date of each payment's receipt or the last day of the taxable year of receipt of that payment. The flexibility is pretty cool. If the installment payment flows to you via K-1, it's possible an even more flexible timing regime would apply as well under the K-1 rules. Therefore, no need to worry about deferring all at once: you may defer as installments are received.

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