The U.S. IRS has published a practice unit on Transfers of Property to Partnerships with a Related Foreign Partner. The process overview of the practice unit includes the following: U.S. persons can transfer built-in gain (appreciated) property in a wide variety of nonrecognition transactions, such as contributions to partnerships in exchange for an interest in the partnership. In general, IRC 721(a) provides for nonrecognition treatment when a partner contributes appreciated property to a partnership. However, in certain cases, such nonrecognition treatment could allow a U.S. person to use a partnership to inappropriately shift the tax consequences of pre-contribution gain attributable...