This is particularly the case for partners who derive no significant benefit from having their gains classified as capital gains.
The underlying reason for this disparity is that sale or liquidation payments are taxed according to the types of partnership property to which they are attributable.
These items are marked with a bright red banner above the bidding box.
Not only does the process produce a third less greenhouse gas emissions than cremation, but it also uses a seventh of the energy and allows for the complete separation of dental amalgam for safe disposal. Well, mercury that is burnt in cremation has been blamed for an astounding 16 percent of UK airborne mercury emissions.
As a result, many crematoriums are installing filtration systems, but more can be done.
However, if the transaction is instead structured as a sale, the departing partner will still have ordinary income under Section 751(a), but the remaining partners will receive no deduction.
(If a Section 754 election is in effect, the remaining partners will of course obtain a basis step-up, which will reduce their ultimate taxes.) If any of the payments to the departing partner are attributable to inventory, it would also generally be preferable to structure the transaction as a liquidation rather than as a sale.
Consider the taxation of payments for unrealized receivables.