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 721 — Index
Section Reference
Section Description
721 Nonrecognition of Gain or Loss on Contribution to a Partnership
721(a) General Rule
721(b) Special Rule
721(c) Regulations Relating to Certain Transfers to Partnerships
721(d) Transfers of Intangibles
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).
END OF DOCUMENT