Subchapter K Part II

Question 1

Subchapter K Part II

Answer 1

Partners and Partnerships 701-777
Contributions Distributions and Transfers 721-755

Question 2

721(a)

Answer 2

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.

Question 3

721(b)

Answer 3

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.

Question 4

721(c)

Answer 4

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.

Question 5

721(d)

Answer 5

Transfers Of Intangibles —

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