@Robert Collins
Pros -
(1) You have longer to re-invest in an exchange or replacement property than 1031 (180 days where-as 1031 you must identify 3 in 45 and close within 180 days on one of the three). @Dave Foster - can correct me if I'm wrong on this one.
(2) If held for ten years, you pay zero capital gains on any and all equity growth of the investment
(3) You defer your original cap gain until 2026 and can reduce it by 15% if you invest in this tax year.
Cons -
(1) You must substantially improve the property. Meaning you buy for $100k and assign $70k to the building, $30k to the land, you must improve the building by $70k.
(2) You must comply with the OZ Fund regulation which typically requires assistant from a securities attorney and CPA with strong knowledge of OZ's.
(3) If you're recruiting capital to come into your deals, it can be difficult getting someone to invest for a ten year hold.
I think that's a wrap for now. Hope this helps.