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Mark is the sole shareholder of T . Corporation. Mark first formed Tex's income double taxed, Mark elected S corporation status for T . several
Mark is the sole shareholder of T Corporation. Mark first formed Tex's income double taxed, Mark elected S corporation status for T several years ago. On Dec. x Tex reports $ of earnings and profits from its years as a C corporation and $ in its accumulated adjustments account from its activities as an S corporation including its x activities
Mark discovered that for the first time, T was going to have to pay the excess net passive income tax. Mark wanted to avoid having to pay the tax, but he determined that the only way to avoid the tax was to eliminated Ts E&P by the end of x He determined that, because of the distribution ordering rules AAA first he would need to have T immediately in x distribute $ to him. this would clear Ts accumulated adjustments account first and then eliminate Ts C corporation earnings and profits in time to avoid the excess net passive income tax.
Mark was not sure Tex could come up with the $ of cash or property in time to accomplish this objective. Does Mark have any other options to eliminated Ts earnings and profits without first distributing balance in Ts accumulated adjustments account?
Use relevant IRC codes to support your answer.
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