Section 721 of the Internal Revenue Code
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
Updated: Sunday, July 30, 2006
| Section Description |
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Nonrecognition of Gain or Loss on Contribution to a Partnership | |
| |
721(a) | |
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721(b) | |
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721(c) | |
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721(d) | Transfers of Intangibles |
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.
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).
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