The opportunity zone regulations that cover dispositions of assets by QOFs and the reinvestment of the resulting proceeds address a different question, which is whether the cash proceeds will be treated as a "good" asset for purposes of qualifying as a QOF before they are reinvested. But there is no provision under the opportunity zone rules that permits the QOF to exclude gain from the disposition of its assets (unless an investor in the QOF has held his or her QOF interest for at least 10 years). To avoid gain from a disposition of its assets, a QOF would have to turn to non-recognition provisions elsewhere in the Internal Revenue Code, such as the rules on like-kind exchanges or reorganizations.
