51) Which of the following statements best describes the role of current and accumulated earnings and profits in determining if a distribution is a dividend?

A) A distribution will only be a dividend if total earnings and profits (current plus accumulated) is positive at the time of the distribution.

B) A distribution can never be a dividend if current earnings and profits are negative.

C) At a minimum, some portion of the distribution will be a dividend if current earnings and profits for the year are positive, even if accumulated earnings and profits are negative.

D) A distribution will never be a dividend if current earnings and profits for the year are negative, even if accumulated earnings and profits is positive.