A QOF can sell its assets and reinvest the proceeds but if this happens before an investors 10 year hold, this will result in taxable gain. A QOF could attempt to use Section 1031 to circumvent this issue, but the marriage of 1031 and QOF could make finding replacement property difficult. Lastly, if the QOZB triggers a gain and passes this through to the QOF and ultimately its investors the investor could contribute this same amount of gain into a QOF to defer the gain again (as long as this happens before the 2026 close of program).