How to structure sponsor promote as Capital Gains?

[Chase Banta]

Here's the structure in our current operating agreement:

Investors get a 6% pref and everything beyond is split 50/50 between investors and sponsor (aside: split is very favorable to sponsor because sponsor brought 75% of capital and personally guaranteed the loan).

Since all original capital has been returned to investors, sale proceeds will be split 50/50 between investors and sponsor.

What I'd like is for the promote to be considered capital gains so it can be invested tax deferred into an Opportunity Zone Fund.

How can I achieve this?