Intel) from a personally titled Ameritrade account into a
new Partnership (LLC) account with Ameritrade. So long as I
maintain a majority control over the Partnership by
receiving the proper percentage of membership interest in
the LLC for the current market value of the stock
transferred, it is my belief that this would not be
considered a taxable event by the IRS under either Section
721, Section 351, or Section 354. My personal basis on
each stock investment would therefore transfer to the LLC
and become the cost basis for each investment that the LLC
The LLC will hold these investments long-term (possibly make
some new purchases with cash) and potentially (yet rarely)
sell and re-invest in other stocks (asset re-allocation).
In a sense, this would be an "investment company / LLC /
partnership". Section 721 and 351 makes note of an
exception to the rule referring to an "investment company"
(as defined in Section 351).
Also, publically held stock may be considered an
"intangible" asset. Could you please explain whether section
(d) of Section 721 ("Transfers of intangibles") needs to be
considered in regards to this transfer in order to keep it a