Extract to table

Section 367(a)(1) provides that, in the case of any exchange described in sections 332, 351, 354, 356, or 361, if the transfer is by a United States person of property to a foreign corporation, the foreign corporation shall not be considered a corporation for purposes of determining the extent to which gain shall be recognized on such transfer

Section 731(b) provides the corresponding rule for the distributing partnership: "[n]o gain or loss shall be recognized to a partnership on a distribution to a partner of property, including money

IRC § 731(c) — Marketable Securities Treated as Money Section 731(c)(1) provides that, for purposes of § 731(a)(1) and (b), "the term 'money' includes marketable securities," and that such securities "shall be taken into account at their fair market value as of the date of the distribution

Section 752(a) provides that any increase in a partner's share of the liabilities of a partnership, or any increase in a partner's individual liabilities by reason of the assumption by such partner of partnership liabilities, shall be considered as a contribution of money by such partner to the partnership

Section 752(b) provides the converse rule: any decrease in a partner's share of the liabilities of a partnership, or any decrease in a partner's individual liabilities by reason of the assumption by the partnership of such individual liabilities, shall be considered as a distribution of money by the partnership to such partner