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For further clarification, according to the U.S. Master Tax Guide (2018): For an S corporation with earnings and profits, unless an election is made to

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For further clarification, according to the U.S. Master Tax Guide (2018): "For an S corporation with earnings and profits, unless an election is made to distribute the earnings and profits as dividends, distributions are treated as: A nontaxable return of capital, to the extent of the corporation's accumulated adjustments account (AAA); Dividends, to the extent of the S corporation's accumulated earnings and profits (AEP); A nontaxable return of capital, to the extent of the shareholder's remaining stock basis; and Gain from the sale or exchange of property (Code Sec. 1368(c); Reg. Sec. 1.1368-1(d)). Before applying these rules, the shareholder's stock basis and the AAA are adjusted for the corporate items passed through from the corporate tax year during which the distribution is made." (par. 323) Why would it be beneficial to make the election to distribute E&P as dividends? What adjustments might need to be made to the AAA, specifically

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