§ 721. Nonrecognition of gain or loss on contribution

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(a)General rule No gain or loss shall be recognized to a partnership or to any of its partners in the case of a contribution of property to the partnership in exchange for an interest in the partnership.

(b)Special rule Subsection

(a)shall not apply to gain realized on a transfer of property to a partnership which would be treated as an investment company (within the meaning of section 351) if the partnership were incorporated.

(c)Regulations relating to certain transfers to partnerships The Secretary may provide by regulations that subsection

(a)shall not apply to gain realized on the transfer of property to a partnership if such gain, when recognized, will be includible in the gross income of a person other than a United States person.

(d)Transfers of intangibles For regulatory authority to treat intangibles transferred to a partnership as sold, see section 367(d)(3).

(Aug. 16, 1954, ch. 736, 68A Stat. 245; Pub. L. 94–455, title XXI, § 2131(b), Oct. 4, 1976, 90 Stat. 1924; Pub. L. 105–34, title XI, § 1131(b)(3), (5)(B), Aug. 5, 1997, 111 Stat. 979, 980.)

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U.S. Code

Recognition of gain on certain transfers to certain foreign trusts and estates
§ 684

11 references not yet in our index

Aug. 16, 1954, ch. 736
68A Stat. 245
Pub. L. 94–455, title XXI, § 2131(b)
90 Stat. 1924
Pub. L. 105–34, title XI, § 1131(b)(3)
111 Stat. 979
section 1131(b) of Pub. L. 105–34
Pub. L. 105–34, § 1131(b)(3)
Pub. L. 105–34, § 1131(b)(5)(B)
Pub. L. 94–455
Pub. L. 94–455, title XXI, § 2131(f)(3)

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§ 721

Nonrecognition of gain or loss on contribution

Fed. Reg.×21

Stat.×6

U.S.C.×2

U.S.C.§ 684

ActAug. 16, 1954, ch. 736

Stat.68A Stat. 245

Pub. L.Pub. L. 94–455, title XXI, § 2131(b)

Stat.90 Stat. 1924

Pub. L.Pub. L. 105–34, title XI, § 1131(b)(3)

Cites 12 · showing 6Cited by 29 across 3 sources