a. Non-recognition of gain or loss on contributions applies only if those persons transferring property to the entity are in control of the entity immediately after the exchange. b. Non-recognition of gain or loss on contributions applies to initial transfers as well as all subsequent contributions to the entity. c. If the transfer of property involves the receipt of money or other consideration, the transaction may be deemed a sale or exchange rather than a tax-free transfer. d. Nonrecognition provisions do not apply to all transfers made by the owners.
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