Bruin Company reports current E&P of $100,000 in 2021 and accumulated E&P at the beginning of the year of negative $100,000. Bruin distributed $150,000 to its sole shareholder on December 31, 2021. The shareholders basis in Bruin is $150,000. How is the distribution treated by the shareholder in 2021?

A. $150,000 dividend

B. $100,000 dividend; $50,000 return of capital

C. $50,000 return of capital; $100,000 capital gain

D. $100,000 dividend; $25,000 return of capital; $25,000 capital gain