Setting up an opportunity zone fund

[Manas M.]

I found several posts about QOZF on BP but don't have a satisfactory answer to this question yet. I know a turnkey property that is doing some new construction in an OZ. I am pretty sure they must be using some of OZ benefits to develop these areas. 

Now, if I setup an LLC as an QOZF and purchase one of these new construction (perhaps with 50% in leverage), would this purchase satisfy all requirements of the OZ program? 50 % of funds would come from my personal funds which are eligible capital gains.

My thoughts are since would be a new construction, it wouldn't require  a "substantial improvement". However, what gives me doubt is that fact that I am not purchasing land and developing from ground up (which would have made this eligible definitely IMO).