Split one land gain across two funds, one deploying now and one waiting for the 2027 designations
Sold a 60 acre piece I'd held since 2014, gain came in at $418k. I didn't want the whole thing sitting in one sponsor's hands for a decade, and I didn't love the idea of committing everything into tracts that are on the current designation list when the map turns over.
So I split it. $220k into an established multi-asset fund with three projects already closed inside current zones, and $190k into a second vehicle from a manager I'd watched for a couple of years, structured so most of the capital gets called after the new designations take effect. The rest went to tax.
The part that nearly killed it was timing. My 180 day window ran from the sale, and the second fund wasn't ready to accept a subscription in a form my CPA was happy with until day 141. I had a signed backup subscription with a third fund sitting in a drawer as insurance, which felt paranoid until day 130. If the second one had slipped another three weeks I'd have wired to a fund I liked less, or paid the tax.
What I'd keep: the backup subscription, and refusing to let one sponsor hold the whole gain. What surprised me is how differently the two managers handled the transition question. One had a written view on what happens to a project in a tract that doesn't get redesignated. The other gave me a phone answer that changed slightly the second time I asked, and that's the one I cut to the smaller check.
Eligibility of any specific tract and the treatment of your particular gain is a question for your tax advisor, mine charged me four hours and it was the best money in the whole deal.