You'd probably need to voluntarily decertify your Qualified Opportunity Fund if the move puts the Qualified Opportunity Zone Business out of compliance. Not sure there's a major financial benefit to be had from relocating in this fashion.
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What happens if I need to move my Qualified Opportunity Zone Business to a different area not in an Opportunity Zone?
How can I best plan this move for maximum financial benefit?
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If your qualified opportunity zone business (QOZB) is no longer in an opportunity zone (or, to be more precise, no longer uses substantially all of its tangible assets in an opportunity zone), then the QOZB will no longer qualify as such, and your qualified opportunity fund's (QOF) interest in the QOZB will no longer be qualified opportunity zone property (QOZP). Depending on the QOF's other assets, this could cause it to fail the 90% test, resulting in penalties and even a loss of QOF status. In order to avoid this result, you'll need to get the QOZB interest out of the QOF. It cannot be distributed without causing an inclusion event (to the extent of the fair market value of the QOZB interest). So one approach would be for the QOF to sell the QOZB interest and then reinvest the proceeds into another QOZB within 12 months.
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