SECTION 7. DRAFTING AND

CONTACT INFORMATION

The principal author of this notice is Maria Castillo Valle of the Office of Associate Chief Counsel (Income Tax & Accounting). For further information regarding this notice, contact Ms. Castillo Valle at (202) 317-7006 (not a toll-free number).

1(b)(3). If property otherwise qualifies as QOZBP, a QOF or QOZB that acquires that property on or before the expiration of its QOZ designation period (December 31, 2027, or December 31, 2028, as applicable), or pursuant to sections 5.01(2) or 5.01(3) of this notice, may continue to treat a previously designated QOZ the designation of which has expired as a QOZ solely for purposes of § 1400Z-2(d) (2)(D)(i)(III) through December 31, 2047.

(3) QOZB Compliance Tests . For an entity to qualify as a QOZB, at least 50 percent of its gross income must be derived from the active conduct of a trade or business in a QOZ, and a substantial portion of its intangible property must be used in the active conduct of a trade or business in a QOZ. See § 1400Z-2(d)(3) (A)(ii); see also § 1.1400Z2(d)-1(d)(3)(i)

and (ii). A QOZB that has begun to engage in the active conduct of a trade or business within a previously designated QOZ on or before the expiration of its QOZ designation period (December 31, 2027, or December 31, 2028, as applicable), or that reasonably anticipates to begin doing so in accordance with a written plan that meets the requirements of section 5.01(2) of this notice, may continue to treat a previously designated QOZ the designation of which has expired as a QOZ solely for the purposes of § 1400Z-2(d)(3)(A)(ii) through December 31, 2047.