26 U.S.C. § 683: Use of trust as an exchange fund

(a) General ruleExcept as provided in subsection (b), if property is transferred to a trust in exchange for an interest in other trust property and if the trust would be an investment company (within the meaning of section 351) if it were a corporation, then gain shall be recognized to the transferor. (b) Exception for pooled income fundsSubsection (a) shall not apply to any transfer to a pooled income fund (within the meaning of section 642(c)(5)).