Our newly forming development group is looking for a structure that allows the partners in the sponsorship entity to take the lions share of the accelerated depreciation, in spite of having 10% or less of equity in th...

We usually would do this as a partnership of some sort.

Basically, the government says you did a good deal on this one, reinvest the full gains (a "partnership" of sorts) with expectations that both your gains and your tax bill will be higher later. 

For this reason many folks will have their single member LLCs elect to file taxes as a partnership. 

The QOZ "funds" are usually structured as LLCs, which means that you are buying or investing in a membership (partnership) interest and not directly into real estate, which does not qualify for 1031 Exchange treatment.  

If there are two members in the LLC, it is likely treated as a partnership for tax purpose. 

@Hemant Rawat I strongly, STRONGLY suggest you use a lawyer that's experienced with partnerships to structure your business relationship.

The borrower(s) may have initially purchased the property as one of the following:a natural person;an eligible inter vivos revocable trust, when the borrower is both the individual establishing the trust and the beneficiary of the trust;an eligible land trust when the borrower is the beneficiary of the land trust; oran LLC or partnership in which the borrower(s) have an individual or joint ownership of 100%.The original purchase transaction is documented by a settlement statement, which confirms that no mortgage financing was used to obtain the subject property.

It doesn't matter if you are an LLC or an S-Corp or a Partnership.

We were fortunate enough to link up with a skilled contractor looking to build a business (which we have done, we own a successful local painting company) and were able to form a partnership that has propelled us years in advance (on the contracting/renovation side) and allowed us to focus on building our acquisition business.