Consequences of a Single Cash Distribution. Clover Corporation is a calendar year taxpayer. Connie owns all of its stock. Her basis for the stock is $10,000. On April 1 of the current (non-leap) year Clover distributes $52,000 to Connie. Determine the tax consequences of the cash distribution in each of the following independent situations:

a. Current E&P of $15,000; accumulated E&P of $25,000.
b. Current E&P of $30,000; accumulated E&P of ($20,000).
c. Current E&P of ($73,000); accumulated E&P of $50,000.
d. Current E&P of ($20,000); accumulated E&P of ($15,000).

Respuesta :

Following are the responses to the given points:

For a:

[tex]\bold{\$40,000}[/tex] Connie will receive a dividend.

[tex]\bold{\$15,000}[/tex] out of current E&P and [tex]\bold{\$25,000}[/tex] out of accumulated E&P;

[tex]\bold{\$10,000}[/tex]  returns capital to Connie, lowering her basis to zero;

The excess  [tex]\bold{\$2,000}[/tex] is taxed as a capital gain.

E&P accumulated just at the start of next year would be zero dollars.

For b:

The current E&P yield is a dividend to Connie is [tex]\bold{\$30,000}[/tex]

[tex]\bold{\$10,000}[/tex] returns capital to Connie, reducing her basis to zero.

The excess [tex]\bold{\$12,000}[/tex]  is taxed as a capital gain.

When next year begins, the accumulated E&P deficit is expected to stand at [tex]\bold{(\$20,000)}[/tex]

For c:

On April 1 (in a non-leap year), Clover's accumulated E&P:

[tex]\to \bold{\$50,000 - [(\frac{\$73,000}{365})\times 90]}\\\\\to \bold{\$50,000 - [(200)\times 90]}\\\\\to \bold{\$50,000 - [18000]}\\\\\to \bold{\$32,000}\\\\[/tex].

Therefore, the taxable as a dividend [tex]\bold{\$32,000}[/tex]

[tex]\bold{\$10,000}[/tex] remaining distribution is taxable as a capital gain and it is used to reduce Connie's stock to zero.

The remaining [tex]\bold{\$10,000}[/tex] distribution is taxable as a capital gain.

Starting next year, E&P will have a [tex]\bold{\$55,000}[/tex] accumulated deficit [tex]\bold{[\$50,000 - \$18,000}[/tex] pro-rata deficit -[tex]\bold{\$32,000}[/tex] dividend - [tex]\bold{\$55,000}[/tex] residual deficit].

For d:

Starting with the return of the capital because E&P deficit

[tex]\bold{\$10,000}[/tex]  returns of the capital which reduces Connie's basis to zero;

Excess [tex]\bold{\$42,000 }[/tex] is taxable as per the capital gain that is [tex]\bold{(52,000-10,000)}[/tex].

The accumulated E&P deficit at the starting of the next year is [tex]\bold{(\$35,000)}[/tex]Learn more:

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