Tax Free Transfer to LLC

I have an S corp client that wants to add some foreign investors. Selling the foreign investor corp stock will terminate the S election. The fmv of the net assets are greater than book value so there is some built-in gain. The foreign investors could then purchase units of the LLC and the company would still maintain its pass-thru characteristics currently allowed by the S Corp.
Is it possible for an S corp to form an LLC by transferring all of its net assets to the LLC tax free under Code Sec. 721(a)?

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