Question
Sunny Hill Corporation has one class of voting common stock, of which 1,000 shares are issued and outstanding. The shares are owned as follows: Aubrey
Sunny Hill Corporation has one class of voting common stock, of which 1,000 shares are issued and outstanding. The shares are owned as follows:
Aubrey Glen 400
Jerry Glen (Aubreys son) 200
Lou Ann Glen (Aubreys daughter) 200
Maggie Mae (unrelated) 200
Total shared 1,000
Sunny Hill Corporation has current E&P of $400,000 for this year and accumulated E&P at January 1 of this year of $60,000. During this year, the corporation made the following distributions to its shareholders:
03/31: Distributed $100/share to each shareholder ($100,000 in total).
06/30: Distributed $100/share to each shareholder ($100,000 in total).
09/30: Distributed $100/share to each shareholder ($100,000 in total).
12/31: Redeemed all of Maggies shares for $250,000 in cash
Sunny Hill Corporation contacted a highly skilled CPA firm, QRS, for their advice on the following issues:
- What is the tax status of each distribution made this year?
- What is the amount of accumulated E&P at the beginning of next year
- Lastly, due to COVID-19, Aubrey is considering retirement and would like to have the corporation redeem all of his shares for $100,000 plus a 10-year note with a fair market value of $300,000. What must Aubrey do or consider if he wants to ensure that the redemption will be treated as an exchange? Could Aubrey still act as a consultant to the company?
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