Qualified opportunity funds (QOFs) pay dividends to their investors like any other corporations (given that question asks about the payment of "dividends," I have limited this answer to QOFs that are corporations). A dividend (as defined by Code Section 316) from a corporate QOF generally will not constitute an inclusion event to an investor in the QOF (by contrast, a distribution from a corporate QOF that exceeds the QOF's earnings and profits and the investor's basis in his stock, and therefore results in gain under Code Section 301(c)(3), will be cause an inclusion event to the investor). The investor would report the dividend in the same manner that he reports any other dividends.
