Prior to the August 2021 amendment, the earliest date that a Qualified Opportunity Fund (QOF) could pick for decertification was the first day of the month following the month in which the QOF makes its election. The amendment removed this constraint and simply requires that the decertification be "effected in such form and manner as may be prescribed by the Commissioner." It appears that a decertification may be retroactive, though the Form 8996 will have to be amended (or other guidance will have to be provided) to state just how far back a QOF can go.