Why the differing treatment of (1) funding with property transferred in exchange for stock with and without "control", (b) the distribution of property and cash to shareholders, (3) why it matters to shareholders, (4) the reason(s) for doing business as a corporation, or (5) any other reason which you consider important. Also, keep in mind the "double taxation" of corporations, the 21% corporate income tax rate, and how dividends are taxed. And consider whether ordinary income can be converted to dividends or capital gain and save taxes.