Transactions Between a Partner and a Partnership

Free CPA TCP (Tax Compliance & Planning) lesson in Entity Tax Compliance. 17 min read, ~2,493 words.

Section 721 provides nonrecognition on property contributions; partner takes substituted basis in the partnership interest equal to basis of property contributed. Partnership takes carryover basis in contributed property and tacks the contributor's holding period. Services exchanged for a capital interest trigger ordinary income equal to FMV; profits interests generally qualify...

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