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an election may be made to treat such sale, exchange, or distribution as a disposition of all of the assets of such other corporation, and no gain or loss shall be recognized on the sale, exchange, or distribution of such stock. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. Release dates appear exactly as we get them from the IRS. This is a list of parts within the Code of Federal Regulations for which this US Code section provides rulemaking authority. Any stock owned by a corporation, trust (other than a trust referred to in subparagraph (B)(iii)[)], or partnership shall be treated as owned proportionately by its shareholders, beneficiaries, or partners, and shall not be treated as owned by such corporation, trust, or partnership.
This is particularly the case for partners who derive no significant benefit from having their gains classified as capital gains.In a sale, by contrast, any payment received upon a purchase of a partnership interest that is attributable to partnership goodwill is generally treated as capital gain and is not deductible by the remaining partners.The collateral consequences of a liquidation also often tend to be more favorable than the collateral consequences of a sale.By contrast, a liquidation of a partner’s interest in the partnership will not cause such a termination, even if the partner has a 50-percent or greater interest in the partnership.It should be noted that several seemingly ancillary tax factors can alter the analysis in choosing between sale and liquidation treatment.