1 окт. 2019 г. · This discussion provides a summary of some of the basic previously taxed earnings and profits ordering rules likely to apply to distributions

14 дек. 2018 г. · Under section 316, distributions are considered first as distributions from current E&P, to the extent thereof, and then as distributions from ...

The ruling in Fujitsu only provided the ordering of distributions with respect to current year E&P. It did not decide how to order distribution from a CFC ...

1 нояб. 2022 г. · E&P and PTEP are used in the classification of distributions from a CFC to U.S. shareholders as dividends, return of capital, and capital gains ...

The Notice provides important guidance and examples related to tracking PTEP and ordering PTEP distributions, including 16 PTEP groups to track annually.

3 окт. 2022 г. · The rules of section 959(c) apply to exclusions of E&P distributions and the rules of section 959(f) apply to exclusions of investments in ...

Accumulated E&P to the extent the distribution doesn't reduce the account below zero. Undistributed Previously Taxed Income (PTI) to the extent the distribution ...

18 июн. 2020 г. · The ordering rules for the AAA are not the same as the ordering rules for stock basis. Distributions are applied to stock basis after current ...

1 апр. 2023 г. · Section 316 to provide that distributions are sourced first from previously taxed earnings and profits (PTEP) before untaxed E&P. Distributions ...

1) Current e&p is allocated proportionately to all current year distributions. · 2) Accumulated e&p is allocated chronologically to distributions during the year ...