Creating a Qualified Opportunity Fund (QOF) to purchase new single family constructions in an Opportunity Zone should be no different than forming any other QOF. If the constructions are in fact new, and have not been occupied, then the original use requirement should be met (so that you don't have to "substantially improve" them). What are you planning to do with the constructions, rent them or sell them? If you are renting them, then you'll need to provide the tenants with services and not just lease them on a triple net basis. If you are just going to sell them off (within the next few years), then you wouldn't get much benefit from a QOF -- the gains from the sales will not be excluded and you'll only be able to defer your invested gain until you've sold off the homes (unless the QOF finds another suitable investment to re-invest the proceeds).
