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26 U.S.C. § 721

Title 26 Chapter 1 Current through PL 119-73 Last updated: March 29, 2026 View on OLRC →
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§ 721. Nonrecognition of gain or loss on contribution

  • (a) 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) 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) 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) For regulatory authority to treat intangibles transferred to a partnership as sold, see section 367(d)(3).

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