1368-4, all of the distribution and AAA rules are in effect for tax years beginning after 1993.
The deemed dividend election also gives rise to an AAA bypass election with respect to any distributions actually made during the year.
P would have bypassed AAA with respect to the $35,000 distributed.
1368-1 (g) (2) (ii) provides that a corporation electing to split tax years must treat the tax year as separate ta-x years in making adjustments to the AAA, E&P and basis.
1, 1997, and makes an AAA bypass election for 1997.
1368-1 (d) (2), the portion of the distribution remaining after the AAA is treated as a distribution of AAA under Sec.
The AAA is the central focus for any distribution from an S corporation with AE&P, because it provides a cushion from dividend treatment.
These awkward distribution rules were changed by the SSRA, which adopted the concept of the AAA.
Thus, a distribution from PTI had the same effect on a shareholder as a distribution from AAA.