Choosing the best legal format for your QOF is dependent upon what your investments will be. In most cases we would recommend that the QOF be structured as an LLC taxed as a partnership. QOZ businesses and real estate investments under the QOF should also generally be LLC/partnerships to allow debt to be counted toward investor basis and to allow early year losses to flow through to the QOF owners. In certain cases, investors may not want the flow-through and a C corp may be more appropriate at the fund or operating entity level. I have yet to see a situation where I would advise using an S corp.