CPA Exam — REG (Regulation)Federal Taxation of EntitiesHard

A client, an S corporation, has an accumulated adjustments account (AAA) balance of $60,000 and accumulated earnings and profits (AE&P) of $30,000. Its sole shareholder, whose stock basis is $120,000, receives a cash distribution of $100,000. What is the amount of the distribution that is considered a taxable dividend?

  1. A$0
  2. B$40,000
  3. C$60,000
  4. D$30,000
Show answer & explanation

Correct answer: D. $30,000

S corporation distributions follow a specific hierarchy when AE&P exists. First, distributions come from AAA, which is tax-free up to the shareholder's basis. Here, $60,000 comes from AAA, reducing it to $0 and the shareholder's basis to $60,000 ($120,000 - $60,000). Next, distributions come from AE&P, which are taxable dividends. The remaining distribution is $100,000 - $60,000 = $40,000. This $40,000 comes from AE&P, but only $30,000 is available as AE&P. Thus, $30,000 is a taxable dividend. The remaining $10,000 ($40,000 - $30,000) reduces the shareholder's basis further. So, the taxable dividend is $30,000.

Why the other options are wrong

  • A. Incorrect. When AE&P exists, distributions exceeding AAA are taxable dividends.
  • B. Incorrect. This would be the amount remaining after AAA, but before considering the limit of AE&P.
  • C. Incorrect. This is the amount from AAA, which is tax-free to the extent of basis.

S Corp Distribution Order (with AE&P)

When an S corporation has accumulated earnings and profits (AE&P), distributions are sourced in a specific order: first from AAA (tax-free up to basis), then from AE&P (taxable dividend), then from basis (tax-free return of capital), finally as capital gain.

  • AAA distributions are tax-free up to shareholder basis.
  • AE&P distributions are taxable dividends.
  • Distributions reduce basis after AAA and AE&P are exhausted.
  • Distributions exceeding basis after AAA and AE&P are capital gains.

Memory trick: AAA First, E&P Second, Basis Then Gain.

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