Can S Corp Have Distributions if Negative M-2
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The taxation treatment of a distribution by an Southward corporation with accumulated East&P depends on the balance of the corporation's accumulated adjustments business relationship (AAA), its E&P, the stock ground of the shareholder who received the distribution, and the order in which adjustments must exist made to these account balances. Office I of this commodity, in the January issue, examined the function a shareholder's ground in Southward corporation stock, earnings and profits (Due east&P), and the accumulated adjustments business relationship (AAA) play in determining the taxability of an S corporation's distributions and the rules for determining the taxability of distributions from an S corporation with no accumulated Eastward&P. In Part 2, this article covers the taxability of distributions from an S corporation with accumulated E&P and ancillary issues and planning opportunities. Earlier reading Office 2, readers should review Part I on the proper adjustments to be made to stock basis, E&P, and AAA before determining how a distribution is taxed.
Taxability of Distributions From S Corporations With Accumulated E&P
When a distribution is made from an S corporation with accumulated Due east&P, it must be analyzed to make up one's mind its source to preserve the unlike treatment of distributions of S corporation income, which should not be taxed a 2nd time, from distributions of C corporation E&P, which must be taxed as a dividend to the recipient shareholder.
Sec. 1368(c) accomplishes this task by dividing a distribution made from an Southward corporation with accumulated E&P into three tiers, determining the taxability to the recipient shareholders as follows:
Tier ane: To the extent the AAA balance is positive, the distribution is treated every bit if made by an South corporation with no accumulated Due east&P.
Tier 2: Distributions in backlog of AAA are treated as dividends to the extent of the accumulated Due east&P residuum.
Tier iii: Distributions in backlog of accumulated E&P are treated every bit fabricated by an S corporation with no accumulated E&P.
While these tiers oft appear disruptive, a closer examination reveals the logic—the goal of preserving the difference between distributions of S corporation income and C corporation E&P.
Past providing that the get-go dollars of distribution are treated as having been made from an Southward corporation with no E&P to the extent of the AAA balance, the regulations permit a corporation to distribute its remaining previously taxed only undistributed income before the corporation will be deemed to have distributed its accumulated East&P. This does non mean, however, that the distribution is tax free; it simply ways that the distribution will not be a taxable dividend. To determine the distribution's taxability, the shareholder must adjust his or her ground in the corporation's stock. As discussed in Part I, the distribution will beginning be treated as a tax-gratis reduction of the shareholder'south stock basis, with any distribution in backlog of footing generating capital proceeds.
One time a distribution has reduced a corporation's AAA to nothing, the regulations rationalize that because all previously earned S corporation income has been distributed, the next dollars of distribution are fabricated from the corporation's accumulated East&P and must be taxed as a dividend until the E&P balance has been reduced to zero.
After the corporation'south accumulated East&P has been fully distributed, the corporation can no longer make a taxable dividend, and, as a issue, the only attribute that becomes relevant to determining the distribution'due south taxability is the shareholder'due south basis in the corporation'due south stock. Thus, the distribution volition over again be treated equally a taxation-free reduction of the shareholder'due south stock basis, with any distribution in excess of basis generating capital proceeds.
When a distribution is made from an S corporation with accumulated East&P, three split up attributes—AAA, E&P, and shareholder's stock basis—must be adjusted to determine the distribution'southward taxability. As the post-obit instance illustrates, the attributes must exist adapted in a specific order.
Example one: A owns 100% of S Co., an S corporation. On Jan. 1, 2013, S Co. has AAA of $2,500 and prior accumulated E&P of $vii,500. Also on January. 1, 2013, A has an adapted basis in S Co. stock of $10,000. During 2013, Due south Co. allocates to A $nine,000 of ordinary income and $two,000 of long-term majuscule loss. S Co. also distributes $11,000 to A.
To determine the taxability of the $xi,000 distribution, the distribution must be divided into three tiers:
Tier i: The $11,000 distribution volition be treated as having come up from an Southward corporation without accumulated Due east&P to the extent of the positive AAA balance. This requires the AAA remainder to be computed commencement.
To adjust S Co.'s first AAA balance of $2,500, it must first be adamant whether Southward Co. has a net positive adjustment or a net negative adjustment for 2013. Because Due south Co.'s $9,000 of income exceeds its $2,000 of losses by $7,000, Due south Co. has a $seven,000 cyberspace positive adjustment. Southward Co. must therefore increase its AAA by the $7,000 net positive adjustment before accounting for the $11,000 distribution.
AAA is increased from $2,500 to $9,500 by the $7,000 internet positive adjustment, leaving S Co. with a positive AAA residue of $9,500. Thus, the first $9,500 of the $11,000 distribution is treated as having come from an S corporation with no accumulated E&P and is not taxed equally a dividend. However, this result does non mean the distribution is taxation free to A; rather, A must determine the $9,500 distribution's taxability by reference to his footing in the S Co. stock.
Tier 2: Tier 1 accounted for only $ix,500 of the $11,000 distribution. The remaining $1,500 distribution is treated as having come from S Co.'s accumulated E&P rest of $7,500, reducing the E&P residual to $6,000. The entire $one,500 distribution made under Tier two is taxed as a dividend, and the resulting dividend income does not increase A's footing in his South Co. stock, nor does this portion of the distribution by Due south Co. reduce S Co.'s AAA or A'south stock footing.
Tier three: The distribution does not exceed the Eastward&P residual, so no portion of the distribution is allocated to Tier 3.
Because of the potential confusion caused by tracking multiple attributes, a distribution should be accounted for in table form, separating the distribution between the portion that is not from E&P and is included in Tiers ane and 3 (cavalcade Southward) from the portion that is fabricated from East&P and included in Tier two (column C), as shown in Exhibit i.
Next, A must adjust his stock basis to determine the taxability of the $9,500 distribution that is included nether Tiers 1 and 3 and non taxed as a dividend (column S), every bit shown in Exhibit ii.
In summary, $9,500 of the $xi,000 distribution is a tax-free reduction of A's stock basis. The remaining $1,500 distribution is taxed every bit a dividend to A.
When a distribution exceeds both AAA and E&P, the remaining distribution is treated every bit having been made from an S corporation with no E&P. Thus, AAA once over again becomes irrelevant in determining the taxability of whatever hereafter distributions.
Example ii:
During 2013, Due south Co. generated $200 of income and a $900 long-term capital loss, resulting in a $700 net negative adjustment. S Co. is required to reduce AAA for the distribution before accounting for the net negative aligning.
S Co. reduces its $200 balance in AAA to zero, but distributions cannot reduce AAA below nada. Therefore, only the first $200 of the $1,000 distribution is included under Tier 1 and treated equally a distribution fabricated from an South corporation with no accumulated E&P. Once AAA has been reduced to goose egg by the distribution, S Co. must next reduce AAA for the internet negative aligning, reducing AAA to a negative balance of $700.
The next $500 of distribution is accounted to take come from S Co.'s accumulated E&P under Tier 2 and is taxed to A as a dividend.
The remaining $300 of distribution is included in Tier iii and is treated as a distribution made from an Southward corporation with no accumulated E&P. Because E&P has been reduced to zero, hereafter Due south Co. distributions will all be taxed under the rules governing S corporations with no accumulated E&P.
The adjustments to AAA and E&P and the allocation of the distribution are illustrated in Exhibit 3.
To determine the taxability of the $500 distribution that was not taxed as a dividend to A, A must arrange his ground in the South Co. stock as shown in Showroom 4.
When an South corporation begins a year with negative AAA, the AAA residue must be restored to a positive balance before the corporation can make a nondividend distribution.
Case 3:
Because S Co. has a cyberspace positive adjustment of $half dozen,000 during 2013 ($10,000 income less $iv,000 loss), Due south Co. must increase its AAA residual before reducing AAA for the $5,000 distribution. The $six,000 increase to S Co.'s AAA is non plenty, however, to restore AAA to a positive balance. Thus, the commencement dollars of distribution are accounted to have come from S Co.'due south accumulated Due east&P and are taxed equally a dividend to A, equally shown in Exhibit five.
The entire $5,000 distribution is made from Due east&P and has no upshot on A's basis in his S Co. stock. A must conform his basis in the S Co. stock as shown in Exhibit 6.
The previous example illustrates the importance of accurately projecting annual income and loss when an South corporation begins the year with a negative rest in its AAA. If the corporation wants to make a nondividend distribution, care must exist taken to ensure that the net positive adjustment for the year will be big enough to restore AAA to a positive balance in backlog of the anticipated distribution.
Because AAA is not increased for tax-exempt income, i an S corporation with accumulated E&P may want to avert property tax-exempt investments, as the resulting income cannot exist distributed revenue enhancement free.
Case 4: A owns 100% of Due south Co., an S corporation. On January. 1, 2013, S Co. has AAA of $0 and accumulated E&P of $one,000. Also, on January. 1, 2013, A has a $1,000 basis in South Co. stock. During 2013, S Co. allocates to A $500 of tax-exempt interest and distributes the $500 to A.
Even though S Co. is distributing income that was included in A'south basis in his S Co. stock, because the tax-exempt income does not increase AAA, the distribution is treated as having come entirely from accumulated E&P, as shown in Exhibit vii. A must adjust his basis as shown in Exhibit 8.
When an S corporation with E&P makes multiple distributions during a yr that exceed the AAA'due south adjusted balance, the distributions do non reduce AAA on a chronological footing; rather, the AAA for the year must be allocated among the distributions by multiplying the adjusted AAA by a fraction, the numerator of which is the amount of the distribution and the denominator of which is the total distributions made during the year. Any remaining corporeality of each distribution is deemed to accept come up from Eastward&P in the club in which the distributions were made. 2
Case five: A owns 100% of S Co., an S corporation. On Jan. 1, 2013, S Co. has $five,000 of AAA and $37,000 of accumulated Due east&P. During 2013, S Co. generates $3,000 of net income. On April one, 2013, S Co. makes a $4,000 distribution to A. On April xxx, A sells his stock to B. On Dec. 31, Due south Co. makes a $12,000 distribution to B.
Because the total distributions of $16,000 exceed S Co.'s adjusted residuum of its AAA of $8,000 ($five,000 beginning balance plus $3,000 net positive adjustment), Southward Co. must allocate a portion of its AAA to each distribution based on the following formula: Adjusted AAA × distributions ÷ total distributions.
Thus, of the $4,000 distribution fabricated from Southward Co. to A, $ii,000 ($viii,000 × $4,000 ÷ $16,000) is treated as having been fabricated from AAA. The remaining $ii,000 of the distribution is treated as having been made from E&P and is taxed as a dividend to A.
Of the $12,000 distribution made from S Co. to B, $6,000 ($8,000 × $12,000 ÷ $sixteen,000) is treated as having been made from AAA. The remaining $six,000 of the distribution is treated as having been fabricated from E&P and is taxed every bit a dividend to B.
When an S corporation redeems a portion of its stock in a transaction qualifying every bit a sale or exchange under Sec. 302(a), the corporation is required to reduce AAA by the proportionate share of stock redeemed. 3
Instance six: A owns 20% of S Co. In 2013, Due south Co. redeems A'south stock for $2,000 when S Co.'s AAA residuum was $v,000. Southward Co. is required to reduce its AAA by 20%, or $one,000, to account for the redemption.
If an ordinary distribution is fabricated in the same yr every bit a redemption, AAA must exist reduced for the ordinary distribution before being reduced for the redemption, regardless of the order in which the distribution and redemption took place. four
Instance 7: Assume the same facts equally in the previous example, except S Co. also makes a $2,000 ordinary distribution to the remaining South Co. shareholders subsequently the redemption of A'due south shares. Although the ordinary distribution occurred after the redemption of A's shares, Southward Co. must showtime reduce AAA from $5,000 to $3,000 to account for the ordinary distribution, and then reduce the remaining AAA balance by $600 ($3,000 × 20%).
Additional Considerations
Property Distributions
When an South corporation distributes appreciated property to its shareholders, Sec. 311(b) provides that the corporation must recognize proceeds as if it sold the property for its fair marketplace value (FMV). 5 For these purposes, the FMV cannot be less than any liabilities to which the holding is subject and that the distributee assumed. 6 Each shareholder must then increase his or her basis in the corporation'due south stock for his or her share of the proceeds. 7
The Due south corporation is so treated as having fabricated a distribution equal to the FMV of the property, less any liabilities the shareholder assumed. 8
Example 8: A owns 100% of S Co., an S corporation. Due south Co. distributes property with a basis of $100 and an FMV of $1,000. S Co. has no accumulated East&P, and A has a ground in Southward Co. stock of $200.
Upon the distribution of the belongings to A, S Co. must recognize gain of $900 under Sec. 311(b). This gain increases A's ground in the S Co. stock from $200 to $i,100. A is then treated as having received a distribution of $1,000, the FMV of the holding. This reduces A's basis from $1,100 to $100, and the entire distribution is tax free.
When belongings is distributed with an FMV that is less than its adjusted tax basis, the S corporation is barred from recognizing a loss by Sec. 311(a). The recipient shareholder is treated as having received a distribution equal to the property's FMV less any liabilities the shareholder assumed. nine This results in a footstep-downwards of basis without the corresponding loss existence recognized by the Southward corporation, making distributions of loss property a bad idea. As an culling, the S corporation should consider selling the property to an unrelated party to trigger the loss, and and then distribute the cash to its shareholders.
Other Adjustments Business relationship
Form 1120S, U.S. Income Taxation Return for an S Corporation, refers to the corporation's other adjustments account (OAA). The OAA reconciles those items that increase or decrease a shareholder'south stock ground but not AAA, primarily revenue enhancement-exempt income and deductions attributable to tax-exempt income. 10 The OAA is purely an administrative reconciling item; it is not contained in the statute or regulations and thus has no bear upon on the taxability of an Due south corporation's distributions.
Previously Taxed Income
Earlier the Subchapter S Revision Act of 1982 11 created AAA on Jan. 1, 1983, the cumulative undistributed income of an Southward corporation was tracked in the previously taxed income (PTI) account. Dissimilar AAA, however, PTI was a shareholder-level aspect. 12 Any PTI attributable to a shareholder on Dec. 31, 1982, was frozen at that time.
A shareholder with pre-1983 PTI may keep to receive distributions from that account. If an S corporation has E&P, a distribution is treated every bit having been made from the PTI account after reducing AAA but earlier reducing E&P. 13 Merely distributions of cash may reduce PTI; belongings distributions in backlog of AAA bypass PTI and are treated as having been fabricated from Eastward&P. xiv
Example 9: S Co. elected to exist taxed as an South corporation on Jan. i, 1980. On that date, South Co. had $20,000 of accumulated East&P. On December. 31, 1982, Due south Co. had $35,000 of PTI allocated to its sole shareholder, A. From 1983 through 2013, South Co. accumulated $150,000 of AAA. On Dec. 31, 2013, S Co. distributes $180,000 to A.
The $180,000 distribution start reduces AAA from $150,000 to zero. The next dollars of distribution come first from PTI rather than E&P. Thus, the remaining $30,000 distribution reduces the PTI account from $35,000 to $5,000, and none of the distribution is treated as having come from E&P. To the extent the $180,000 does non exceed A'south basis in the South Co. stock, it will be tax complimentary; to the extent it exceeds A'southward stock basis, it will generate capital gain.
Distributions After Termination of the S Election
When an Southward corporation revokes or terminates its S election, it reverts to being treated as a C corporation, and under the full general rules of Secs. 316 and 301, any distributions by the corporation would first be treated equally having been made from current or accumulated East&P and taxed as a dividend. However, merely as Sec. 1368 is designed to ensure that distributions of E&P are taxed as a dividend when made from an S corporation, Sec. 1371(e)(1) allows an Southward corporation with AAA that revokes or terminates its Southward ballot to distribute its ending residual of AAA earlier the distribution will be treated as having been made from a C corporation. 15 To authorize for this handling, the distribution must come across several requirements. Offset, the distribution must be made in greenbacks, non property. Next, the distribution must be fabricated during the post-termination transition menses (PTTP). xvi
The PTTP begins on the mean solar day after the terminal mean solar day of the corporation's concluding tax year every bit an S corporation and ends on the later of two dates: 17
- One year from that date, or
- The due date of the final Due south corporation return, including extensions.
In add-on, the statute provides for an additional PTTP in the outcome of a subsequent IRS inspect. This period runs from:
- The 120-twenty-four hours period beginning on the date of any determination from an inspect of the corporation that follows the termination of the corporation's election and that adjusts a subchapter S item of income, loss, or deduction that arose during the S corporation menstruum, and
- The 120-day period beginning on the date of a decision that the corporation's subchapter S ballot had terminated for a previous tax twelvemonth.
During the PTTP, a distribution by a former South corporation will be treated every bit having get-go been made from the final balance of its AAA. 18 Only after AAA is reduced to zero are distributions treated as having come up from a C corporation. xix
Case x: On Dec. 31, 2012, S Co., an S corporation, revokes its S election when S Co. has an AAA residue of $twenty,000 and an E&P residual of $40,000. On June one, 2013, S Co. distributes $twenty,000 to its shareholders. Fifty-fifty though S Co. is now a C corporation, because the $twenty,000 distribution was fabricated during the PTTP, it is treated as having been made from S Co.'s final AAA balance rather than from Eastward&P. The distribution will outset stand for a tax-gratis reduction of the recipient shareholders' basis in the corporation's stock, with whatsoever excess distribution generating capital gain.
Whatsoever remaining PTI balance owing to an Southward corporation shareholder does not survive the termination of the S election and may not be distributed during the PTTP. Thus, an South corporation that plans to revoke its S election—or anticipates its South condition terminating—should have steps to distribute PTI earlier the revocation or termination to ensure that the distribution will not be taxed as a dividend. xx
Optional Elections to Distribute Eastward&P Earlier AAA and PTI
In certain situations, an S corporation with accumulated East&P may wish to distribute E&P before distributing its AAA residual. For example, the corporation may have "backlog internet passive investment income" under which the presence of E&P may trigger corporate-level tax or may terminate the S election. 21 Alternatively, a shareholder may wish to receive a taxable dividend in order to use an expiring net operating loss. Or, every bit was the case at the finish of 2012, the threat of increasing tax rates on dividend income may prompt an S corporation to purge its Eastward&P rest before rates ascension.
An S corporation with pregnant AAA or PTI, nonetheless, will confront challenges in distributing its E&P balance under the general rules because the corporation may not possess enough cash to distribute the AAA and PTI balances. Fortunately, the regulations provide three elections that enable a corporation to reverse the general ordering rules and distribute E&P before distributing AAA or PTI.
Nether Regs. Sec. ane.1368-1(f)(2), a corporation may elect to distribute AAA after E&P. Thus, the first dollars distributed during the year are taxed equally a dividend, and simply after E&P is fully purged is a distribution treated equally having been made from AAA.
Example 11: Due south Co., an Southward corporation, has $40,000 of AAA and $20,000 of E&P on Dec. 31, 2012. S Co. distributes $xx,000 to its shareholders during 2012.
Anticipating rising tax rates on dividend income, S Co. elects to bypass AAA and have the distribution treated as having been fabricated first from E&P. As a result, the entire $xx,000 distribution is taxed equally a dividend to S Co.'s shareholders, reducing S Co.'s Due east&P remainder from $xx,000 to $0.
Note, even so, that if a corporation that makes the election to distribute AAA after East&P still has PTI allocable to a shareholder, the PTI balance continues to be distributed before E&P, making the distribution order PTI-Eastward&P-AAA. This result may be desirable if the corporation plans to revoke its Southward status because, as previously discussed, the PTI balance cannot be distributed revenue enhancement costless during the PTTP.
Instance 12: Assume the same facts in Example 11, except Due south Co. also has $20,000 of PTI attributable to its shareholders. S Co. plans to revoke its S election during 2013. If S Co. makes the election nether Regs. Sec. 1.1368-1(f)(ii), the $20,000 distribution will first be treated as having been made from PTI, and none of the distribution volition be taxed every bit a dividend.
If the goal is to take Due east&P distributed earlier both AAA and PTI, however, a 2d election is available that, when made in conjunction with the election to bypass AAA, volition change the ordering rules over again. This election, in Regs. Sec. 1.1368-ane(f)(four), allows an Due south corporation to distribute Eastward&P before AAA and PTI, making the distribution lodge E&P-AAA-PTI and permitting the start dollars of distribution to be taxed equally a dividend to the recipient shareholders. 22
Example 13: Assume the same facts as the previous case, except S Co. also makes the election under Regs. Sec. ane.1368-ane(f)(4) to bypass PTI. The $20,000 distribution will first be treated as having come from E&P and will exist taxed as a dividend.
If a corporation does not have the cash necessary to purge its E&P balance, the regulations let the corporation to make a deemed distribution of all or part of its Due east&P balance. The deemed distribution is treated as having been received past the shareholders and immediately recontributed to the Southward corporation, providing the recipient shareholders with an increase to their basis in the stock.
Upon making this election, the corporation is treated every bit having besides made the election to bypass AAA.
Example xiv: Southward Co., an S corporation, has $40,000 of AAA and $20,000 of E&P on December. 31, 2012. Southward Co. does not accept any cash available to distribute, merely anticipating rising tax rates on dividend income, S Co. wishes to fully purge its E&P. S Co. files an election under Regs. Sec. one.1368-1(f)(3) to brand a accounted dividend of $20,000. Equally a issue, S Co. is treated as having fabricated a greenbacks distribution of $20,000 to its shareholders, who in turn are treated as having immediately recontributed the $xx,000 to Southward Co.
These elections are irrevocable and apply only for the year for which they are made. All three elections must be made on an original or amended return by the extended due date for that tax twelvemonth, and each shareholder who received an actual or deemed distribution during the year must consent to the ballot. 23 This timing provides the benefit of hindsight. For case, an S corporation that does not make a cash distribution in year 1 may discover in year 2 that tax rates on dividend income accept increased essentially. Provided the ballot is fabricated on an original or amended render past the extended due appointment for the twelvemonth i tax return, Due south Co. may purge its E&P before the rates increment.
While at showtime chroma Sec. 1368 and the related regulations announced to present a maze of tiers, attributes, and ordering rules, recognizing the consequences arising from an South corporation distribution should non present a particularly daunting challenge for a practitioner who has a business firm agreement of the intent of the distribution rules and the relevant shareholder- and corporate-level attributes that bulldoze a distribution'south taxability.
Footnotes
1 See the discussion in Function I, in the Jan 2022 issue.
2 Regs. Sec. i.1368-3, Example (eight).
3 Regs. Sec. one.1368-two(d)(1)(i). A similar rule applies to the reduction in accumulated Due east&P. See Sec. 312(n)(7).
four Regs. Sec. 1.1368-2(d)(1)(ii).
5 Via Sec. 1371(a).
half-dozen Sec. 336(b).
vii The corporate-level gain likewise increases AAA, but it should non increase E&P. Note, the corporation does not pay tax on the proceeds recognized under Sec. 311(b) unless the gain is subject to the built-in gains rules of Sec. 1374.
8 Sec. 301(b). The FMV of the distributed property should reduce AAA—but not beneath nothing—to the extent the distribution is non taxed as a dividend. If the distribution is taxed as a dividend, the property's FMV should reduce E&P.
9 If the distribution is taxed as a dividend, the reduction to E&P is limited to the ground of the property nether Sec. 312(a)(iii).
10 Also included in the OAA are payments of revenue enhancement attributable to prior C corporation years. These payments should presumably reduce any accumulated East&P of the S corporation from prior C corporation years.
xi Subchapter S Revision Human activity of 1982, P.L. 97-354.
12 Equally a result, if a shareholder with PTI sold his stock, the transferee shareholder would not inherit the transferor shareholder's PTI residue.
xiii Regs. Sec. 1.1368-1(d)(2).
14 Id.
15 Nevertheless, an S corporation tin can elect under Sec. 1371(e)(2) to non accept this rule apply.
xvi Sec. 1371(due east)(1).
17 Sec. 1377(b).
xviii Sec. 1371(e).
19 Note, because taxation-exempt income does not increase AAA, taxation-exempt investments are still not advisable fifty-fifty if the South corporation has no E&P, considering the tax-exempt income volition not exist permitted to exist distributed during the PTTP.
xx Delight see the ensuing discussion regarding the ballot bachelor to distribute PTI before E&P and AAA.
21 Secs. 1362(d)(3) and 1375.
22 Regs. Sec. one.1368-1(f)(four). Alternatively, if an S corporation desires to make its distribution order AAA-E&P-PTI, it would brand the election under Regs. Sec. 1.1368-1(f)(4) to distribute E&P before PTI, merely not the election under Regs. Sec. 1.1368-ane(f)(2) to distribute E&P before AAA.
23 Regs. Sec. 1.1368-1(f)(5).
| EditorNotes | |
| Tony Nitti is a partner with WithumSmith+Brown PC in Aspen, Colo. For more information near this article, contact Mr. Nitti at anitti@withum.com. |
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