DESCRIPTION
This module provides an overview of the tax rules governing contributions of property and liabilities to partnerships, including the general nonrecognition provisions and basis implications. It also introduces the concept of pre-contribution (built-in) gains. The module highlights the character rules for certain types of contributed property and the impact of liabilities on partner basis. Key anti-abuse provisions are discussed at a high level to illustrate how the rules prevent inappropriate shifting of tax consequences. Practical examples are used to reinforce how these principles apply in common partnership scenarios.
LEARNING OBJECTIVES
- Explain the general rules governing the contribution of assets to a partnership under IRC §§721 and 724.
- Summarize the treatment of pre-contribution gain under partnership tax rules.
- Evaluate the impact of liability contributions and debt-encumbered property on partner basis and gain recognition.

