TaxGuided
United States IRC sections

Statute section

IRC section 721

Nonrecognition of gain or loss on contribution

Country

United States

Section

721

Updated

2026-05-20

Operative text

Section 721 generally provides nonrecognition treatment when a partner contributes property to a partnership in exchange for a partnership interest. There are important exceptions for transfers to investment partnerships and for the disguised-sale rules of Section 707(a)(2)(B).

Cross-references

26 U.S.C. 70726 U.S.C. 722

Primary sources

Important disclaimer

This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.