Last year, Miley decided to terminate the S corporation election of her solely o
ID: 2526500 • Letter: L
Question
Last year, Miley decided to terminate the S corporation election of her solely owned corporation on October 17, 2016 (effective immediately), in preparation for taking it public. At the time of the election, the corporation had an accumulated adjustments account balance of $180,000 and $475,000 of accumulated E&P from prior C corporation years, and Miley had a basis in her S corporation stock of $157,500. During 2017, Miley’s corporation reported $0 taxable income or loss. Also, during 2017 the corporation made distributions to Miley of $95,000 and $70,000.
How are these distributions taxed to Miley assuming the following? (Leave no answer blank. Enter zero if applicable. Enter N/A if not applicable.)
c. The first distribution was a property (noncash) distribution (fair market value of distributed property equal to basis) and was paid on June 15, 2017; the second distribution was a cash distribution, and was paid on September 30, 2017.
State the Amount taxable for the dates below:
June 15
September 30
Explanation / Answer
Because the June 15 distribution is not in cash it is a dividend to Miley to the extent of the corporation's earnings and profits. Here Miley must recognize $95,000 of dividend income.
So on June 15 - 95000
On September 30 - 0
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