Whether a transfer of a Qualified Opportunity Fund (QOF) interest between individuals will be an inclusion event (i.e., a triggering of deferred gain) depends on the type of the transfer, rather than on the relationship between the individuals. A transfer of a QOF interest by an individual to his spouse or same-sex partner by reason of his death generally will not be an inclusion event, but neither will a bequest to any other person. Conversely, an individual's sale, gift inter vivos, or transfer in connection with divorce, to his spouse generally will be an inclusion event.