(a) Partnerships and limited liability companies subject to taxation as corporations pursuant to Subtitle A of the Internal Revenue Code of 1994.-Any partnership or limited liability company subject to taxation as a corporation pursuant to the provisions of Subtitle A of the Puerto Rico Internal Revenue Code of 1994, during the last taxable year beginning prior to January 1, 2011, and which for the first taxable year beginning after December 31, 2010, is subject to taxation under the provisions of this chapter shall be considered that, on the last day of the last taxable year beginning prior to January 1, 2011, transferred its assets and liabilities to its partners and members, as the case may be, in liquidation of the partnership or limited liability company and, immediately after, the partners and members, as the case may be, contribute the assets and liabilities distributed to a new partnership in a transaction subject to the provisions of § 30341 of this title. Except as provided in this subsection, no gain or loss shall be recognized to the partnership limited liability company and partners or members thereof, as the case may be, as a result of the distributions made under

d in this subsection, no gain or loss shall be recognized to the partnership limited liability company and partners or members thereof, as the case may be, as a result of the distributions made under this subsection. Except as otherwise provided in this Code, such partnership or limited liability company shall be subject to the provisions of subsections (d), (e), (f), (g) and (h) of § 30583 of this title and § 30588 of this title.(b) Partnerships and limited liability companies subject to taxation under the provisions of Subchapter B of Chapter 2 or under Subtitle A of the Puerto Rico Internal Revenue Code of 1994, pursuant to § 30076 of this title.- Any partnership or limited liability company that, prior to the taxable year during which it is subject to taxation under this chapter, was subject to taxation under the provisions of Subchapter B of Chapter 2 or under Subtitle A of the Puerto Rico Internal Revenue Code of 1994 pursuant to § 30076 of this title shall be considered that, on the last day of such year, transferred its assets and liabilities to its partners or members, as the case may be, in liquidation of the partnership or limited liability company in a transaction

t, on the last day of such year, transferred its assets and liabilities to its partners or members, as the case may be, in liquidation of the partnership or limited liability company in a transaction subject to the provisions of § 30144(q) of this title, and immediately after, the members or partners, as the case may be, contributed the assets and liabilities distributed to the new partnership in a transaction subject to the provisions of § 30341 of this title. Except as otherwise provided in this Code, such partnership or limited liability company shall be subject to the provisions of subsections (d), (e), (f), (g) and (h) of § 30583 of this title and § 30588 of this title. History —Jan. 31, 2011, No. 1, § 1076.01, retroactive to Jan. 1, 2011; Dec. 10, 2011, No. 232, § 92.