These are referred to as inclusion events and were detailed out in the Final Regulations. They range from items such as gifting/transferring the interest to another individual to property distributions from a Qualified Opportunity Fund where fair market value is greater than the partner's basis.
Most of these transactions involve a change in responsibility for the deferred gain, which the regulations do not allow. However, some of these transactions do not involve such a change and would trigger the deferred capital gain even though there is non-recognition from an income tax point of view and the same beneficial owner is responsible for the gains. Inclusion events are to be navigated with the assistance of counsel; laypeople shouldn't be analyzing this on their own.
The regulations contain very detailed rules on the types of transactions that are said to be "inclusion events" that trigger deferred gains. In general, a taxpayer should seek the assistance of a tax professional before (i) making any transfer of a qualifying investment of a Qualified Opportunity Fund (QOF) (even if the transfer would otherwise be tax-free, such as a gift); (ii) receiving a distribution from the QOF; or (iii) claiming a worthlessness deduction for the qualifying investment. Not every transaction described in the foregoing will necessarily constitute an inclusion event, but the various exceptions are too involved to discuss here. In addition, a loss by a QOF of its qualification as such will also be an inclusion event.
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