![]() (ii) The AAA is decreased under paragraph (a)(3)(i) of this section (without taking into account any net negative adjustment (as defined in section 1368(e)(1)(C)(ii)) before it is decreased under paragraph (a)(3)(iii) of this section (i) The AAA is increased under paragraph (a)(2) of this section before it is decreased under paragraph (a)(3)(i) of this section for the taxable year For any taxable year of the S corporation beginning on or after August 18, 1998, the adjustments to the AAA are made in the following order. (5) Ordering rules for the AAA for taxable years beginning on or after August 18, 1998. (iv) The AAA is adjusted (whether negative or positive) for redemption distributions under paragraph (d)(1) of this section. (iii) The AAA is decreased (but not below zero) by any portion of an ordinary distribution to which section 1368 (b) or (c)(1) applies and (ii) The AAA is decreased under paragraph (a)(3)(i) of this section before it is decreased under paragraph (a)(3) (iii) of this section (i) The AAA is increased under paragraph (a)(2) of this section before it is decreased under paragraph (a)(3) of this section for the taxable year For any taxable year beginning before January 1, 1997, the adjustments to the AAA are made in the following order. (4) Ordering rules for the AAA for taxable years beginning before January 1, 1997. The AAA is decreased (but not below zero) by any portion of a distribution to which section 1368 (b) or (c)(1) applies. (iii) Decrease to the AAA for distributions. However, in any subsequent taxable year in which the loss, deduction, or noncapital, nondeductible expense is treated as incurred by the corporation with respect to the shareholder under section 1366(d)(2) or § 1.1367-1(g) (or in which the loss or deduction is otherwise allowed to the shareholder), no further adjustment is made to the AAA. The AAA is also decreased by the entire amount of any loss or deduction even though a portion of the loss or deduction is not taken into account by a shareholder under section 1366(d)(1) or is otherwise not currently deductible under the Internal Revenue Code. The AAA is decreased by noncapital, nondeductible expenses under paragraph (a)(3)(i)(C) of this section even though a portion of the noncapital, nondeductible expenses is not taken into account by a shareholder under § 1.1367-1(g) (relating to the elective ordering rule). The AAA may be decreased under paragraph (a)(3)(i) of this section below zero. (D) The sum of the shareholders' deductions for depletion for any oil or gas property held by the corporation described in section 1367(a)(2)(E). (2) Expenses related to income that is exempt from tax and (1) Federal taxes attributable to any taxable year in which the corporation was a C corporation and (C) Any expense of the corporation not deductible in computing its taxable income and not properly chargeable to a capital account, other than. (B) Any nonseparately computed loss determined under section 1366(a)(1)(B) ![]() ![]() (A) The items of loss or deduction described in section 1366(a)(1)(A) The AAA is decreased for the taxable year of the corporation by the sum of the following items with respect to the corporation for the taxable year. ![]() (iii) The excess of the deductions for depletion over the basis of property subject to depletion unless the property is an oil or gas property the basis of which has been allocated to shareholders under section 613A(c)(11). (ii) Any nonseparately computed income determined under section 1366(a)(1)(B) and (i) The items of income described in section 1366(a)(1)(A) other than income that is exempt from tax The AAA is increased for the taxable year of the corporation by the sum of the following items with respect to the corporation for the taxable year: For the adjustments to the AAA in the case of redemptions, liquidations, reorganizations, and corporate separations, see paragraph (d) of this section. The AAA is increased in the manner provided in paragraph (a)(2) of this section and is decreased in the manner provided in paragraph (a)(3) of this section. ![]() On the first day of the first year for which the corporation is an S corporation, the balance of the AAA is zero. The AAA is relevant for all taxable years beginning on or after January 1, 1983, for which the corporation is an S corporation. The accumulated adjustments account is an account of the S corporation and is not apportioned among shareholders. § 1.1368-2 Accumulated adjustments account (AAA). ![]()
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |