A QOF can be organized as a corporation or as a partnership for the purpose of investing in qualified opportunity zone property. You will need to ask a tax expert regarding the REIT structure tax issues. I don't have that answer.
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What entities can be structured as a QOF?
And If I were to structure as a REIT, would I be fully disqualified from the step-up tax break, or just the portion that was taken as income?
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