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Disproportionate liquidating distributions

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The IRS said in final regulations adopted in 1992 that disproportionate distributions will not automatically indicate a second class of stock (which would automatically terminate the S corporation status) as long as the disproportionate distributions are not required by a Treasury Reg.

section 1.1361-1(l) states “a corporation is treated as having only one class of stock if all outstanding shares of stock of the corporation confer identical rights to distribution and liquidation proceeds”.

(ii) The payment by S of state income taxes on behalf of its nonresident shareholders are generally treated as constructive distributions to those shareholders.

Because S’s resident shareholders have the right to equal distributions, taking into account the constructive distributions to the nonresident shareholders, S’s shares confer identical rights to distribution proceeds.

Although a corporation is not treated as having more than one class of stock so long as the governing provisions provide for identical distribution and liquidation rights, any distributions (including actual, constructive, or deemed distributions) that differ in timing or amount are to be given appropriate tax effect in accordance with the facts and circumstances. Determination of whether stock confers identical rights to distribution and liquidation proceeds.

Accordingly, S is not treated as having more than one class of stock by reason of the agreements. Under section 7872, E is deemed to receive a distribution with respect to S stock by reason of the loan.Accordingly, S is not treated as having more than one class of stock by reason of the employment agreements, even though S is not allowed a deduction for the excessive compensation paid to D. Different premium amounts are paid by S for each employee-shareholder.The facts and circumstances do not reflect that a principal purpose of the agreements is to circumvent the one class of stock requirement of section 1361(b)(1)(D) and this paragraph (l).In addition, S is not treated as having more than one class of stock by reason of the payment of fringe benefits. The facts and circumstances do not reflect that a principal purpose of the loan is to circumvent the one class of stock requirement of section 1361(b)(1)(D) and this paragraph (l).(ii) Under paragraph (l)(2)(i) of this section, the loan agreement is not a governing provision.Sometimes an S corporation will mistakenly pay distributions that are not proportionate, sometimes it will do it intentionally for various reasons and catch up in later years.