Section 723 - Basis of property contributed to partnership

2 Analyses of this statute by attorneys

  1. The Tax-Deferred Rollover – Some Considerations

    Rivkin Radler LLPDecember 14, 2021

    IRC Sec. 362 in the case of a corporation. IRC Sec. 723 in the case of a partnership. Reg. Sec. 1.1001-1(a). IRC Sec. 351(b).

  2. PE Fund, Foreign Investor, No Blocker, & Partnership Rollover – Hiccup?

    Farrell Fritz, P.C.Louis VlahosSeptember 23, 2019

    Reg. Sec. 1.707-3(f), Ex. 1. IRC Sec. 1012. IRC Sec. 723. The HC would then drop down the contributed interest to its subsidiary, following which the subsidiary will own all of the equity in the target partnership, and the target will become a disregarded entity for tax purposes.