Question
(3) Now assume that Ys basis in its X stock is $100 and As basis in his stock is $40. On January 2 of the
(3) Now assume that Ys basis in its X stock is $100 and As basis in his stock is $40. On January 2 of the current taxable year, X distributes $100 in cash to Y and $100 in cash to A. As of the end of the preceding taxable year, Xs accumulated E&P was zero. What are the tax consequences of this distribution to X, Y, and A? [Hint: First compute Xs current-year taxable income and then compute current-year E&P before reducing the E&P for the distribution (interim E&P); after reducing the distribution, compute the final accumulated E&P.] Variation: How much dividend would Y and the holders of As shares receive if As shares were owned by a different shareholder every quarter and $50 was distributed ratably to all shareholders quarterly?
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