I'm not sure that this answers the question, but you could consider having the Qualified Opportunity Funds (QOF) invest in minority portions of several QOZBs (Qualified Opportunity Zone Businesses), rather than having each QOF take nearly all of the interests in a particular QOZB. The key here is that each QOF needs to acquire its interest in a QOZB directly from the QOZB; it cannot acquire the interest from another QOF.