Here are some resources I used.
“Only capital gains, and not ordinary gains, are eligible for the QOZ tax benefits (including short-term capital gains and Section 1231 and 1250 gains). Taxpayers that are eligible for the QOZ tax benefits generally are individuals, partnerships, C corporations, S Corporations, trusts, real estate investment trusts, and regulated investment companies.”
https://www.cozen.com/news-resources/publications/2025/opportu[product key removed]-the-one-big-beau...
“Generally, any capital gain from any source can qualify for the QOF rollover treatment.
The gain being rolled over need not have anything to do with Opportunity Zones or QOFs (e.g., facebook stock gain qualifies).
- This includes short-term capital gain, 1231 gains, 25% “unrecaptured section 1250 gain,” and certain mark-to-market gain (but not ordinary mark-to-market income).
- However, it does not seem to include gain recaptured as ordinary income
- Gain may be triggered intentionally in order to qualify for a rollover
- Note that exchanges of real property must be structured to avoid a 1031 like-kind exchange if the goal is to trigger gains to use in a QOF. Section 1031 is not elective”
https://www.jw.com/wp-content/uploads/2019/10/QOF-deck-10-2019.pdf
