Depreciation on this step up basis is specifically allocated to the acquiring partner. Opportunities for income-splitting or reduction in overall family taxes. Transfer might not qualify for exclusion for gift tax purposes. Must be present interest. Rights over business assets may not be solely retained by donor.
Donee has right to participate in management.
At least one general partner 16. Limited liability 17. Limited partner has no participation in management. Death, insanity, or retirement of a limited partner does not dissolve partnership. Limited partner's interest is transferable.