A Qualified Opportunity Fund (QOF) cannot invest in another QOF, but they can partner to invest in Qualified Opportunity Zone Business Fund (QOZB)'s side-by-side.
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How can two QOFs partner with each other to create a large fund?
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Because a QOF can’t invest into another QOF, the only way for two QOFs to partner with each other is through a section 381 merger (applicable to corporations), or a section 708(b)(2)(A) merger (applicable to partnerships).
They can either merge or form a QOZB joint venture.
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