SECTION 3. DEFINITIONS

.01 Effectively connected gain . The term “effectively connected gain” means the amount of net gain (if any) that would have been effectively connected with the conduct of a trade or business within the United States if the partnership had sold all of its assets at their fair market value as of the date of the transfer described in section 864(c)(8)(A). .02 Transfer . The term “transfer” means any sale, exchange or other disposition. .03 Transferor . The term “transferor” means any person that transfers a partnership interest, and includes a person that receives a distribution from a partnership. .04 Transferee . The term “transferee” means any person that acquires a partnership interest by transfer, and includes a partnership that makes a distribution. .05 Related person . The term “related person” is a person that is related within the meaning of section 267(b) or section 707(b)(1).