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2105, Jan. 18, 1984] §1.316–2 Sources of distribution in general. (a) For the purpose of income tax-ation every distribution made by a cor-poration is made out of earnings and profits to the extent thereof and from the most recently accumulated earn-ings and profits. In determining the source of a distribution, consideration
28 lut 2015 · The amendments made by subsections (f) and (g) [amending this section and sections 331, 333, 551, and 562 of this title] shall apply to distributions made in any taxable year of the distributing corporation beginning after December 31, 1963.
See section 316 and §1.316– 2 for provisions relating to the alloca-tion of earnings and profits among dis-tributions. (2) Previously taxed income. This para-graph (d)(2) applies to distributions by a corporation that has both accumu-lated earnings and profits and pre-viously taxed income (within the meaning of section 1375(d)(2), as in ef-
INCOME TAX. T.D. 9914, page 1000. This document contains final regulations providing guidance on the definition of an eligible terminated S corporation and rules relating to distributions of money by such a corporation after the post-termination transition period.
Section 318 (a) (5) (B) provides that stock constructively owned by an individual by reason of ownership by a member of his family shall not be considered as owned by him for purposes of making another family member the constructive owner of such stock under section 318 (a) (1).
Sec. 316. Dividend Defined. I.R.C. § 316 (a) General Rule — For purposes of this subtitle, the term “dividend" means any distribution of property made by a corporation to its shareholders— I.R.C. § 316 (a) (1) — out of its earnings and profits accumulated after February 28, 1913, or. I.R.C. § 316 (a) (2) —
Section 316 (b) (2) (B) and this subparagraph apply only to distributions made in any taxable year of the distributing corporation beginning after December 31, 1963. The amount designated with respect to a noncorporate distributee may not exceed the amount actually distributed to such distributee.
