You'll need to look at the inclusion event regulations to make sure you don't run into any issues, but there are no requirements per se under the OZ rules. You may need to look to other sections of the Code to see what rules exist for mergers of corporations, mergers of partnerships, and mergers of different entity types with each other. The IRS currently doesn't have any special reporting for QOF mergers, but perhaps they'll create this reporting in the future.