SECTION 1. PURPOSE

This notice announces that the Department of the Treasury (Treasury Department) and the Internal Revenue Service (IRS) intend to issue proposed regulations regarding qualified opportunity zones (QOZs) under §§ 1400Z-1 and 1400Z-2 of the Internal Revenue Code (Code) ¹, as amended by § 70421 of Public Law 119-21, 139 Stat. 72 (July 4, 2025), commonly known as the One, Big, Beautiful Bill Act (OBBBA), including transitional guidance related to qualifying investments under §§ 1400Z-1 and 1400Z-2, as in effect prior to amendment by § 70421 of the OBBBA (forthcoming proposed regulations). The forthcoming proposed regulations are anticipated to include proposed rules similar to the rules provided in sections 3 through 5 of this notice.