Year-End Tax Calendar for Non-Traded REIT and BDC Holders (2026)

How to read the calendar

Three kinds of date sit in the tables below, and they fail differently.

• Statutory or IRS dates. They come from the Code, a regulation or an IRS form instruction, and the source column names it. If one lands on a weekend or holiday, 26 U.S.C. 7503 treats the act as timely on the next day that is not a Saturday, Sunday or legal holiday; the weekday shifts below are our arithmetic.
• Fund dates. A fund sets its own tender or repurchase deadline in a filing, and the source column gives the form and accession number. A tender can be extended, and the offer says so (“unless extended”). Some windows price after they close: Priority Income Fund's offer expires October 30, 2026 but prices at NAV on October 31, 2026.
• Dates we derived. Day counts for 1031 exchanges and the 61-day wash sale window are our arithmetic from the rule cited.

If you are looking for one form's date only, three pages of ours go deeper on one clock each: the 1099-DIV dates and what 17 funds promise, the K-1 dates and the 1031 clock for a late-2026 sale. This page puts them on one line with the tender deadlines and the IRA and loss dates.

October 2026

First Eagle Real Estate Debt Fund's October deadline was October 7, 2026 and has passed; its notice says the next one is January 6, 2027 (our read of that fund).

November 2026

December 2026

January 2027

February and March 2027, plus April 1 and 15

Which tender windows reach December 31

Most of the fund rows above are interval-fund notices with a request deadline. The big non-traded BDCs and several evergreen funds work differently: a Schedule TO-I opens a window of about a month, and the window can end in one tax year and pay in the next. Here is what each did in the offers we read, with the filing date and the expiry stated in the offer. “Latest” means the offer that opened in the third quarter of 2026.

Dates are those stated in the offers and the filing dates on EDGAR. KKR Real Estate Select Trust and Golub Capital Private Credit Fund are the two whose offers opened in Q4 2025 closed after year-end; their latest offers are still open, expiring October 16 and October 28, 2026, with Golub's payment expected November 4. Apollo Debt Solutions' page, Blackstone Private Credit Fund's page, Blue Owl Credit Income's page, Ares Strategic Income's page, KKR FS Income Trust's page, North Haven Private Income Fund's page, StepStone's page and JPMorgan Private Markets Fund's page carry the proration history behind each.

Two cautions before you read this as a plan. First, a pattern is not a promise: each fund's board decides each quarter whether to offer, how much, and when, and several of the funds in the table have prorated holders who tendered more than the cap (see their pages). Second, the table gives the expiry, not the date the shares are treated as sold; the offers we read give an expiration date, a valuation date and a payment date, and the sale date for a particular holder is what the fund's 1099-B shows.

The wash sale rule and a tender

The premise that the wash sale rule does not reach non-traded shares sold back in a tender is not what the sources say. The statute, 26 U.S.C. 1091(a), disallows a loss from a sale or other disposition of “shares of stock or securities” where “within a period beginning 30 days before the date of such sale or disposition and ending 30 days after such date, the taxpayer has acquired” substantially identical stock or securities. The text names no market, and the regulation calls the span the “61-day period” (26 CFR 1.1091-1(a)). IRS Publication 550 adds that buying the same stock for your IRA inside the window is a wash sale too (our reading: that includes an IRA that holds the same fund).

A tender document and a prospectus show how funds describe it. Blue Owl Credit Income's tender document says: “Under the ‘wash sale’ rules of the Code, recognition of a loss on Shares sold pursuant to the Offer ordinarily will be disallowed to the extent a shareholder acquires substantially identical Shares within 30 days before or after the date the Shares are purchased by the Company pursuant to the Offer.” And BREIT, whose repurchases are made as of the opening of the last calendar day of each month, says in its prospectus that most investors “will have their cash distributions automatically reinvested in additional shares of our common stock unless they elect to receive their distributions in cash” (our reading: a reinvestment on the monthly record date is a purchase inside the window).

Where the tender differs from a market sale is Section 302. StepStone's offer says a sale in the offer is a sale or exchange only if the receipt of cash meets one of three tests, and that “If the requirements of Section 302(b) of the Code are not met, amounts received by a Shareholder who sells Shares pursuant to the Offer will be taxable to the Shareholder as a ‘dividend’”. A dividend result leaves no loss to harvest (our reading). Blue Owl Credit Income's document says it is generally anticipated that most shareholders who tender would satisfy one of its three tests; ask your preparer which side you are on, especially for a partial tender. Our tax-loss harvesting page for crowdfunding investments covers the loss rules for Reg A and LLC interests.

Three clocks that cross New Year

• The 1031 clock. The 45-day and 180-day periods run from the closing, not from the calendar year. A November 16 closing puts day 45 on December 31, 2026; a December 31 closing puts it on February 14, 2027 and gives an individual 105 days if the return is not extended (our arithmetic). Section 1031(a)(3) is the statute; the regulation's “earlier of the 180th day … or the due date (including extensions)” is the cut. The 1031 timeline page works every closing date.
• The December distribution paid in January. The 1099-DIV instruction treats a dividend declared in October, November or December and paid in January as received on December 31, so the cash arrives in 2027 and the tax is a 2026 item. The 1099-DIV page has 17 funds' stated mailing dates and the return-of-capital table shows how 2025 distributions were finally split.
• The first RMD. An IRA owner who turns 73 in 2026 can wait until April 1, 2027, but the 2027 RMD is then also due December 31, 2027 (our reading of Publication 590-B). A non-traded fund inside the IRA complicates it; our RMD page on illiquid IRA assets covers that. A QCD counts toward the RMD, but a QCD cannot be made to a donor-advised fund.

DST owners and crowdfunding investors are on the same statutory rows, with a different tender picture: a DST has no tender window, and what a sponsor sends in January is in the sponsor's tax letter (how K-1 and 1099 funds differ; what DSTs charge).

What a holder can do with this

• Put the fixed dates in the calendar first: October 15, December 31, January 15 (and February 1), February 16, March 15 and April 1, then add your own funds' windows from the tables.
• For each fund you hold, look for its last Q4 offer in the rhythm table, and check the fund's filings in early November for this year's: that tells you whether the window ends before December 31.
• If you may sell at a loss, list your purchases and reinvestments from 30 days before to 30 days after the intended sale date, in every account including IRAs, and look at whether distributions are reinvested automatically.
• Ask the fund or your broker which date the 1099-B will show for a tender, and ask your preparer whether a partial tender passes the Section 302 tests.
• If you are over 70½, ask your IRA custodian for its QCD cut-off now: the distribution must be made by the trustee by December 31.
• Do not count on an extension of a tender. An offer can be extended, but nothing in the filings makes a December 31 date certain.

The person who can say whether any of this applies to you is a CPA or tax attorney who has your return; this page is a calendar, not a match to one. If a fund extends or files a new window, the dates above change, and the alert below follows that.

FAQ

Sources, read and saved on October 12, 2026: 26 U.S.C. 401, 408, 1031, 1091, 6072, 6654 and 7503 (United States Code, 2024 edition, as published by the Government Publishing Office) and 5 U.S.C. 6103; 26 CFR 1.170A-1, 1.1031(k)-1, 1.1091-1, 1.6031(b)-1T and 301.7503-1 on the eCFR (text as of September 30, 2026); IRS Notice 2025-67; IRS Publications 526, 550 and 590-B (2025); Form 1040-ES (2026); Form 4868 (2025); Instructions for Form 1099-B (2026), Form 1099-DIV, Forms 1099-R and 5498 (2026), Form 1065 (2025), Form 7004 (Rev. December 2025) and the General Instructions for Certain Information Returns (2025); the BREIT prospectus 424B3 0001628280-25-037857; and SEC EDGAR Schedule TO-I and Form N-23c-3A filings by each fund named, with accession numbers in the tables and in the CSV. Weekday-adjusted dates, day counts and counts of funds are our arithmetic. Tender and repurchase dates are those in each fund's filing on the date read and can be extended. This is analysis of public documents, not investment, legal or tax advice.