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U.S. IRS Releases Practice Unit on Taxability of Distributions Not from Accumulated Earnings & Profits

26 August 2020

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Approved Changes

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United States

The U.S. IRS has released an international practice unit, Taxability of Distributions Not from Accumulated Earnings & Profits. The practice unit addresses the taxability of distributions from an S corporation that either (1) does not have accumulated earnings and profits (AE&P), or (2) makes distributions from sources other than AE&P; that is, nondividend distributions made from the accumulated adjustments account (AAA), other adjustments account (OAA), or a shareholder-level previously taxed income account (PTI) from before 1983 to the extent it still exists. The Practice Unit also addresses what items to consider to determine the taxability of nondividend distributions, liquidating distributions,...