This provision is said to give a taxpayer the "best of both worlds" as it allows the favorable capital gains tax rate on section 1231 property while avoiding the negative implications of capital loss treatment. Ordinary losses are 100% deductible, while capital losses are subject to an annual deduction limitation of $3,000 against ordinary income. Within this framework, if capital losses exceed capital gains by more than $3,000 in any given tax year, the portion of the deduction that may be used to offset ordinary income is limited to $3,000; the excess loss over $3,000 must be carried over to the following year.