Chapt Corporate NoBaiquidating
1 Chapter 4: Corporate Non-liquidating Distributions
NON-LIQUIDATING DISTRIBUTIONS (1 of 2) Non-liquidating distributions in general Computing current E&P Current vs, accumulated e&P Non-liquidating property distributions Constructive dividends
2 NON-LIQUIDATING DISTRIBUTIONS(1 of 2) Non-liquidating distributions in general Computing current E&P Current vs. accumulated E&P Non-liquidating property distributions Constructive dividends
NONLIQUIDATING DISTRIBUTIONS (2 of 2) Stock dividends and stock rights Stock redemptions Preferred stock bailouts Redemptions by related corporations 3
3 NONLIQUIDATING DISTRIBUTIONS(2 of 2) Stock dividends and stock rights Stock redemptions Preferred stock bailouts Redemptions by related corporations
Non-liquidating Distributions (1 of 2 Dividend distributions a distribution of property based upon a corporations earnings profits Property includes money, securities other assets Does not include stock or stock rights of distributing corp Dividends treated as by s/h
4 Non-liquidating Distributions (1 of 2) Dividend distributions –A distribution of property based upon a corporation’s earnings & profits –Property includes money, securities & other assets –Does not include stock or stock rights of distributing corp –Dividends treated as by s/h
Non-iquidating Distributions (2 of 2) Earnings and profits(E&P) E&P not defined in the code E&P consists of current accumulated Distributions are based upon current E&P first accumulated e&P second Distributions in excess of e&P are considered a return of capital
5 Non-liquidating Distributions (2 of 2) Earnings and profits (E&P) –E&P not defined in the Code. –E&P consists of current & accumulated –Distributions are based upon current E&P first & accumulated E&P second –Distributions in excess of E&P are considered a return of capital