The asset-by-asset approach shouldn't affect relocations of an existing operating business. In fact, I doubt it affects operating businesses at all, unless those businesses also have real estate. The problematic part is large real estate projects. For instance, suppose I purchase a parcel with land and an existing building. Without touching the existing building, I construct two more buildings of equal size and value on different sections of the parcel. Even if I back out the land as per the revenue ruling on the subject, I theoretically have 2/3 good assets and 1/3 bad assets, which fails my requirement that my QOZB have at least 70% of its assets be QOZBP. The IRS has certainly received comments on this (including mine), but how they respond remains to be seen.