Gifting is an inclusion event, so you'd have to accomplish this through a grantor trust in favor of your grandchild.
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How can I create a Qualified Opportunity Fund and give as an investment holiday gift to my grandchild?
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I hate to be a grinch, but you really can't gift a qualified opportunity fund (QOF) interest to a grandchild without causing an inclusion event (which will then negate any opportunity zone benefits to him/her). You could gift an appreciated capital asset to the grandchild, have him/her hold it for a period of time (to avoid assignment of income issues) and then direct him/her to sell the asset and invest the resulting gain in a QOF.
As for a gift, you can grant the grandchild a portion of the sponsor equity.
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