Extract to table

The statutory requirements for nonrecognition treatment under § 721(a) are straightforward: there must be a contribution of "property" to a "partnership" in exchange for an "interest in the partnership

The carryover basis rule of § 723 provides that the basis of property contributed to a partnership by a partner shall be the adjusted basis of such property to the contributing partner at the time of the contribution

34 billion in liabilities must be analyzed at each tier

When property with a built-in gain is contributed by one partnership to another in a § 721(a) transaction, the § 704(c) layers must be preserved and carried over to the receiving partnership

The allocation method election is treated as attaching to the property rather than to the entity, such that the receiving partnership must continue to use the same allocation method that the contributing partnership employed

The receiving partnership steps into the shoes of the contributing partnership with respect to the § 704(c) layers and must allocate the built-in gain among its partners in a manner consistent with § 704(c)(1)(A)