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Article: S corporation AAAs and C corporation AE&Ps. (accumulated adjustment accounts, accumulated earnings & profits)
- Article from:
- The Tax Adviser
- Article date:
- January 1, 1993
- Author:
CopyrightCOPYRIGHT 1993 American Institute of CPA's. This material is published under license from the publisher through the Gale Group, Farmington Hills, Michigan. All inquiries regarding rights should be directed to the Gale Group. (Hide copyright information)
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The proposed Sec. 1368 regulations released June 9, 1992 for S distributions apparently might require combining positive and negative accumulated adjustment accounts (AAAs) of constituent S corporations after a merger of the corporations (Prop. Regs. Sec. 1.1368-2(d)(2)). Previous guidance under Sec. 1368 included Letter Ruling 9009.051, which concluded that the positive AAAs of constituent S corporations in a statutory merger should be combined. However, Letter Ruling 9046036 concluded that the positive and negative AAAs of constituent S corporations would be segregated after a merger, citing Sec. 381(c)(2). Prop. Regs. Sec. 1.1368-2(d)(2) refers to a merger of the AAAs ...
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