Summary
A case study is used to illustrate the ways in which a tax adviser can help a client to structure a stock redemption so as to qualify for sales or exchange treatment. Given the case facts, the redemption may only qualify as a sale or exchange by qualifying as a distribution not equivalent to a dividend in which a shareholder receives a meaningful reduction in interest. The disproportionate interest test is also discussed.
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Extract
Structuring a redemption.
FACTS: Basic Corporation is an S corporation that has been successful for several years. Basic once was a regular C corporation and has accumulated earnings and profits (AE&P) of $250,000. Distributions in past years have left the corporation with an accumulated adjustments account (AAA) balance of only $20,000. The two shareholders, Bert and Chuck, are not related. Of the corporation's 1,000 shares of outstanding voting common sto...
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