Most should be a pass-through S corp or partnership or LLC.
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What is a passthrough QOF and how can it be used?
How is a passthrough QOF different from a regular one?
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The difference is the same as if it were not an Opportunity Zone fund - a pass-through entity is an S corporation, LLC, or partnership vs. a C corporation which is not a pass-through entity.
There's no real distinction in the rules between a pass-through QOF and a "regular one;" rather, a QOF can either be a pass-thru entity for tax purposes (a partnership or an S-Corp) or a C-Corp. A QOF REIT would be a blend between both - a C-Corp with special treatment akin to a pass-through. The difference is in tax treatment, which might be significant depending on what's important to you.
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