26 U.S.C. § 683
Use of trust as an exchange fund
# (a) General rule
Except as provided in subsection (b), if property is transferred to a trust in exchange for an interest in other trust property and if the trust would be an investment company (within the meaning of section 351) if it were a corporation, then gain shall be recognized to the transferor.
# (b) Exception for pooled income funds
Subsection (a) shall not apply to any transfer to a pooled income fund (within the meaning of section 642(c)(5)).
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