In other words, if I have owned the property for a certain length of time, would that same holding period apply to my investment in the QOF, or would the holding period restart at the time of the transfer?
Sure, holding period ought to tack, but you would have bigger problems on the OZ compliance side; the property would likely not be eligible for QOZBP treatment, and you'd have mixed investment treatment to the extent of built-in gain. Ground leasing is just a better idea here.
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