Compare hte provision for the nonrecognition of gain or loss on contributions to a partnership (i. e., § 721) w ith the similar provision related to corporate formation (i. e., § 351). What are the major differences and similarities?

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Haylie

Today, 05:41

Compare hte provision for the nonrecognition of gain or loss on contributions to a partnership (i. e., § 721) w ith the similar provision related to corporate formation (i. e., § 351). What are the major differences and similarities?

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Kendal Russell · Answer 1

answer is given below

Explanation:

As a general rule, both Sections 721 and 351 do not realize any gain or loss after a property loss or loss is recognized. How 351 applies as soon as it is exchanged, but 721 does not require regulation. Second 721 applies not only to the spread of p but also to the initial transfer of all contributions from any partner. Under Sec 721, the subscriber must obtain interest for the Pip, and under Section 351 the calf and the transferee must acquire stock in the corporation. Under both, if there are money or other considerations in the transfer of property, the transaction is considered a sale or exchange rather than a tax-free transfer.