I think your question is can you fund your QOF contribution with cash and a note paying off the note overtime to complete the contribution. Further, I think you want to know if the portion of the contribution that is a note qualifies for the working capital exception. First, you have to contribute cash to your QOF equal to the amount of the gain you're deferring. The amount of the note does not qualify as a QOF investment. If the note represents amounts you consider future gain deferrals paying off the note as the gains are realized, there are structuring options but they are more complex than I can explain here. Second, only assets contributed to a Qualified Opportunity Zone Business or a Qualified Opportunity Zone Property are eligible for the 31-month working capital exception. Moreover, the 90% test and the working capital exception are generally unrelated tests. 90% of the QOF assets must be invested in a QOZB or QOZP generally within 180 days of the contribution to the QOF. The working capital exception relates to the assets held by the QOZB or QOZP that have been downstreamed from the QOF entity.