It depends on whether or not the property is transferred to the qualifying opportunity fund (QOF) in a nonrecognition transaction. If it is, then the portion of the QOF interest that is a qualifying investment will be limited to the lesser of the fair market value of the QOF interest and the basis in the property transferred. That is, no portion of the QOF interest that is attributable to built-in gain in the property will be treated as a qualifying investment, and you will have a bifurcated interest in the QOF interest. On the other hand, if the property is transferred to the QOF in a taxable transaction, then the amount of your qualifying investment will be equal to the fair market value of the transferred property.