You should be able to merge both, QOF corporations (with each other) and QOF partnerships (with each other). There is no conflict of which I'm aware between the OZ rules and the Section 708 regulations. In any merger, one entity survives and at least one entity terminates, but QOF status ought to continue in the surviving entity with no penalty for the terminating entity. The IRS has not yet released any guidance about how to report a QOF merger, but I would surmise any merging QOFs should attach statements to their IRS Forms 8996 to clearly report what has happened.