Section 704(c)(1)(A) governs the taxation of unrealized appreciation and loss in property contributed to a partnership. The principles underlying §704(c)(1)(A) also apply to property held by a partnership when additional property is contributed to the venture or existing property is distributed...

The statutory definition of a partnership is the “relation which subsists between persons carrying on a business in common with a view of profit”. Those persons could be natural persons, or other legal entities such as companies or trustees. However, a registered company under the Companies...