S corporation one-class-of-stock regulations reissued: the Service backs off
Article Abstract:
In Aug 1991 the IRS proposed new regulations for implementing the rule that S corporations may not have more than one class of stock that replaced earlier proposed regulations issued in Oct 1990. Under the new rules the one-class-of-stock rule can be violated only by having instruments treated as a second class of stock or by having all outstanding shares of corporate stock confer the same rights to distribution and liquidation proceeds. The new rules merit scrutiny since there is no statute of limitations on S status.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1992
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Tax Court holds current year's losses and adjustments reduce S corporation AAA before distributions
Article Abstract:
The Tax Court in Williams v. Commissioner held that the accumulated adjustments account of an S corporation must be adjusted for the current year before stockholder distributions. The method of accounting is important for determinations of what distributions are treated as ordinary dividends. The opinion correctly reflects legislative intent underlying IRC sections 1367 and 1368.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1999
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Redemption distribution treated as dividend reduces S corporation's accumulated adjustments account
Article Abstract:
The author discusses IRS revenue ruling 95-14 regarding a S corporation's redemption distribution being treated like a dividend for taxation purposes.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1996
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