(a)
In general— Subsection (a) of
section 118 of the Internal Revenue Code of 1986 is amended by inserting before the period at the end the following: “, and, in the case of a partnership, gross income shall not include contributions to the capital of the partnership”.
(b)
Basis of property contributed to partnership— Section 723 of such Code is amended—
(1)
by striking “The basis of property” and inserting the following:
“(a) In general—Except as provided in subsection (b), the basis of property”
(2)
by adding at the end the following new subsection:
“(b) Contributions to capital
“(1) Property other than money—If property other than money—
“(A) is acquired by a partnership as a contribution to capital, and
“(B) is not contributed by a partner as such,
“(2) Money—If money—
“(A) is received by a partnership as a contribution to capital, and
“(B) is not contributed by a partner as such,”
(c)
No increase in basis of partner’s interest— Subparagraph (B) of section 705(a)(1) of such Code is amended by inserting “(other than amounts excluded from gross income under section 118)” after “exempt from tax under this title”.
(d)
Conforming amendment— The heading for section 118 of such Code is amended by striking “of a corporation” and inserting “of corporations and partnerships”.
(e)
Effective date— The amendments made by this section shall apply to contributions made after the date of the enactment of this Act.
(f)
No inference— Nothing contained in this section or the amendments made by this section shall be construed to create any inference under the Internal Revenue Code of 1986 with respect to the treatment of contributions to the capital of partnerships made on or before the date of the enactment of this Act.