Irc Section 721

99 5 issue what are the federal income tax consequences when a single member domestic limited liability com pany llc that is disregarded for federal tax purposes as an entity separate from its owner under 301 7701 3 of the procedure and administration regulations becomes an.

Irc section 721. Contributions to a partnership. This outline illustrates primarily through a. Taxable as corporations and section 721 which applies to transfers of property to entities taxable as partnerships as more or less identical provisions that produce substantially similar federal income tax consequences.

721 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. 721 b special rule. The transaction provides investors with a way of increasing their liquidity and diversification of their real estate investments while deferring very costly capital gains and depreciation recapture taxes that may result from the sale of properties.

Transferor to comply with the requirements in paragraphs b 2 and 3 of this section using the forms and schedules specified in paragraphs b 2 and 3 of this section with the u s. Nonrecognition of gain or loss on contribution. For more detailed codes research information including annotations and citations please visit westlaw.

A section 721 c partnership with a return filing obligation under section 6031 must provide the relevant information necessary for the u s. The phased retirement program was signed into law by the moving ahead for progress in the 21st century act. Internal revenue code section 721 a nonrecognition of gain or loss on contribution.

These benefits are paid primarily under the civil service retirement system csrs or the federal employees retirement system fers. Internal revenue code 721. Nonrecognition of gain or loss on contribution.

Nonrecognition of gain or loss on contribution on westlaw findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system. Transferor s schedule k 1 form 1065 partner s share of income deductions credits etc. For the latest information about developments related to pub.