§ 721. Nonrecognition of gain or loss on contribution
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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. |
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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. |
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(c) |
Regulations relating to certain transfers to partnerships |
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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. |
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(d) |
Transfers of intangibles |
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For regulatory authority to treat intangibles transferred to a partnership as sold, see section 367(d)(3). |
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