You'd have them in two separate QOZBs. The downside to doing this is that non-compliance in one end of the venture could have an impact on the eligibility of the other end. We would usually do this in two separate QOFs.
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How do I best structure a QOF if I want to include both commercial development and business ventures?
And what are the cons of having a mixed asset fund compared to one focused on a single asset group?
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For liability protection purposes, you of course want to set up each development and business venture in a separate LLC, under your qualified opportunity fund (QOF). Each of these LLCs could be a separate qualified opportunity zone business (QOZB) (in which case a second person would have to hold at least a 1% interest in the LLC), or as wholly owned subsidiaries under a QOZB "holding company" owned by the QOF. Whichever you decide depends in part on what helps you meet the 70% / 90% assets tests and the 31/62 month periods under any applicable working capital safe harbor (for example, if you have two projects and their combined development will take longer than 62 months, then you would want them in separate QOZBs). Assuming that you have some form of siloed structure under the QOF, I can't think of any cons from an OZ perspective of combining developments and business ventures under the same QOF.
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