Title 26 - Internal Revenue Code
Sub Title A - Income Taxes
Chapter 1 - Normal Taxes and Surtaxes
Subchapter O - Gain or Loss on Dispostion of Property
Part III - Common Non-Taxable Exchanges
Section 721 - Index
Section 721 - Nonrecognition of Gain or Loss on Contribution to a Partnership
(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).
back to top