Chapter 4 corporate nonliquidating distributions speed dating amsterdam hoger opgeleiden
However, the preferred stock was redeemable in whole or in part at the option of the board of directors at any time at 6 per share plus its proportion of the earnings of the company at the time of such redemption.
In 1910 the preferred stock was issued at 6 per share, for a total of 6,000 and the common stock was issued, at 0 per share, for a total of 0,000.
Thus, if there is a deficit in earnings and profits on the first day of a taxable year, and the earnings and profits for such taxable year do not exceed such deficit, no dividends paid deduction would be allowed for such taxable year with respect to a distribution in liquidation; if the earnings and profits for such taxable year exceed the deficit in earnings and profits which existed on the first day of such taxable year, then a dividends paid deduction would be allowed to the extent of such excess.
( Section 562(b)(1)(B) provides that in the case of a complete liquidation occurring within 24 months after the adoption of a plan of liquidation the amount of the deduction is equal to the earnings and profits for each taxable year in which distributions are made.
The M Corporation, a calendar year taxpayer, is completely liquidated on November 1, 1955, pursuant to a plan of liquidation adopted April 1, 1955.
On January 1, 1955, the M Corporation has a deficit in earnings and profits of 0,000.
The preferred stock was to receive annual dividends of per share and 0 per share on complete liquidation of the corporation in priority to any payments on common stock, and was to participate equally with the common stock in either instance after the common stock had received a similar amount.
for purposes of determining dividends eligible for the dividends paid deduction, refers only to a dividend described in section 316 (relating to definition of dividends for purposes of corporate distributions).
No distribution, however, which is preferential within the meaning of section 562(c) and § 1.562-2 shall be eligible for the dividends paid deduction.
On January 1, 1958, N Corporation had a deficit in earnings and profits of ,000.
During the period January 1, 1958, to the date of liquidation, July 1, 1958, the N Corporation has earnings and profits of ,000.