Property Distributions of Subchapter S Corporations: Regulation 1.1373-1(e) (2) Allocations Not Always Necessary.
本文解释了S类子公司向股东进行财产分配时，如何确定税收后果，重点分析了当期利润分配规则及其对股东税务处理的影响。
Abstract This article informs that there is often a great deal of difficulty in determining the tax consequences of a property distribution in the hands of the shareholders of a Subchapter S corporation. Much of the difficulty is attributable to the manner in which the current earnings and profits (CE&P) of the corporation are allocated to the property distribution. These allocations are employed only for purposes of determining the tax status of the distribution in the hands of the shareholders. These allocations are not made at the corporate level. At the corporate level, all actual distributions are charged first to the corporation's CE&P, once CE&P are exhausted, any remainder is charged against the accumulated earnings and profits of the corporation. The tax consequences surrounding a property distribution by a Subchapter S corporation are often difficult to determine. These allocations are made only for purposes of determining the tax consequences to the shareholder of the corporation. From the standpoint of the distributing corporation, most of the regular SubchapterC rules apply.