Internal Revenue Code (Title 26 U.S.C.)
26 U.S.C. § 721
Nonrecognition of gain or loss on contribution
# (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).
Source: view the official text
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