Treatment of liquidating
(ii) read as follows: “For purposes of clause (i), any property described in clause (i)(I) acquired by the liquidating corporation during the 2-year period ending on the date of the adoption of the plan of complete liquidation shall, except as provided in regulations, be treated as part of a plan described in clause (i)(II).” Subsec.
Stock considered to be owned by a person by reason of the application of the preceding sentence shall, for purposes of applying such sentence, be treated as actually owned by such person.
Public companies usually pay dividends on a fixed schedule, but may declare a dividend at any time, sometimes called a special dividend to distinguish it from the fixed schedule dividends.
If the stock is a capital asset in the shareholder’s hands, the transaction qualifies for capital gain or loss treatment.
The tax treatment of distributions from any trust to its beneficiaries is the same, regardless of whether the trust is effective before or after the grantor’s death.
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Generally speaking, the Roth IRA holder must be at least age 59.5 when the distribution occurs for it to be a qualified distribution.After his time at Price Waterhouse, he served as a Senior Managing Director at FTI Consulting.Sometimes companies that you own make distributions that are eligible for special tax treatment and do not have to be reported as regular dividend income.Because the income of S corporations is taxed to the owners when the income is earned, a mechanism is needed to ensure that the shareholder is not taxed again when the earnings are distributed.
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This is done through a system of rules that track and adjust the shareholder’s stock basis.Distribution to shareholders may be in cash (usually a deposit into a bank account) or, if the corporation has a dividend reinvestment plan, the amount can be paid by the issue of further shares or share repurchase.
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