To accomplish this, you'll need to make the reinvestment using a different tax deferral provision in the Internal Revenue Code, such as Section 1031 or Section 1045. There is no tax deferral treatment for a normal sale and reinvestment inside of a QOF prior to the 10-year period elapsing.
The fund will have to pay taxes on the gain on disposition of the building unless other deferral provisions (1031, for example) are put in place.
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