Several types of transfers are exempted as private transfers not involving trading:
- Transfers in which the basis of the partnership interest in the hands of the transferee is determined by reference to its basis in the hands of the transferor, or under I.R.C. § 732 (property distributed by a partnership to partners).
- Transfers at death.
- Transfers between family members.
- Transfers involving the issue of interests by the partnership in exchange for cash, property, or services.
- Transfers involving distributions from a retirement plan or IRA.
- Block transfers, i.e., the transfer by a partner and any related person, in one or more transactions in any 30-day period, of interests representing more than 2 percent (in aggregate) of total interests in partnership capital or profits.
- Transfers pursuant to a right under a qualifying redemption or repurchase agreement.
- Transfers pursuant to a closed-end redemption plan.
- Transfers by one or more partners of interests totaling, in the aggregate, 50 percent or more of total interests in partnership capital and profits, in one or a series of transactions.
- Transfers not recognized by the partnership. Transfers pursuant to a closed-end redemption plan.
- Transfers by one or more partners of interests totaling, in the aggregate, 50 percent or more of total interests in partnership capital and profits, in one or a series of transactions.
- Transfers not recognized by the partnership.
Treas. Reg. §1.7704-1(e)