Same as other rules.
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How do partnership tax rules apply if a QOF is structured as a partnership for federal tax purposes?
How do partnership tax rules apply if a QOF is structured as a partnership for federal tax purposes?
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The entity is simply taxed as a partnership. The OZ rules are an overlay of rules and regulations that must be complied with to secure OZ tax benefits.
Partnership tax rules apply to a QOF just as they would for any other type of partnership.
All partnership tax rules apply in this case, the QOF structure does not change any of that.
The partnership tax rules apply as normal, but with respect to mixed investments or different "blocks" of partnership interests for OZ purposes, the unitary basis rule does not apply, but only in the OZ context. So you would approach the accounting and tax law analysis the same way, but when evaluating the OZ consequences, you would look to the final regulations and analyze OZ impacts separately from all other partnership tax issues.
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