You have to avoid the cross-referenced disguised sale rules, meaning any leveraged distributions must occur at least two years after contributions in order to put the law in your favor. But leveraged distributions can certainly provide the necessary liquidity to meet the tax liability arising in 2026.
Leveraged distributions from a Qualified Opportunity Fund (QOF) are evaluated under the rules for disguised sales. If the leveraged distribution is made more than two years after funds are contributed to the QOF, it is presumed not to be a disguised sale, meaning the leveraged distribution can be made to QOF investors without triggering early recognition of their deferred gain.
I assume that you are thinking of the tax liability on the gain that must be recognized on Dec. 31, 2026, (and not gain from an inclusion event). You generally can receive a leveraged distribution from a Qualified Opportunity Fund (QOF), so long as (i) the amount of the distribution doesn't exceed your tax basis in the QOF interest, which will be increased by your allocable share of the debt, and (ii) the distribution occurs at least two years after the date that you acquire your QOF interest (so that the so-called "disguised sale" rules don't apply).
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