section 1250 gain can be ordinary income (referred to in IRC 1250 as additional depreciation) which does not qualify for QOF. REG 1.400Z2(a)-1. Section 1250 gain can be a subset of 1231 gain - not ordinary income - taxed at a higher rate than pure capital gain.
from IRC SEC 1250
(b)Additional depreciation defined
For purposes of this section—
(1)In general
The term “additional depreciation” means, in the case of any property, the depreciation adjustments in respect of such property; except that, in the case of property held more than one year, it means such adjustments only to the extent that they exceed the amount of the depreciation adjustments which would have resulted if such adjustments had been determined for each taxable year under the straight line method of adjustment.
however as to QOF there some tricky language
this is what I found
The (new tax) law does not extend the deferred realization date for any capital gains invested in QOZs prior to 2027, which remains December 31, 2026.
here a link to some info from the IRS but it does not cover the new law.
https://www.irs.gov/credits-deductions/opportunity-zones-frequently-asked-questions
I could find nothing that suggest a way to avoid recognizing gain for a pre 2027 QOF investment
