The IRS recently issued extensive regulations under the authority of Section 721(c) that denies nonrecognition treatment for transfer of appreciated property to a controlled partnership (domestic or foreign) by a U.S. person if there are related foreign partners.
I have a prepared a map diagram (viewable in any browser) that provides an overview of the new provisions. Its purpose is to generally familiarize you with the new rules - you will need to review the rules themselves for full detail (translation: do not rely on the diagram since it is an abbreviated summary only).
Here is the link to download the map diagram - again, open it with any browser program. When you have it open, click the ovals with numbers in them wherever you see them to fully expand each map section - they look like this:
Treasury Decision 9814