CCH Learning Center

Description:

A constructive dividend occurs when the IRS or the courts recharacterize a transaction as a deemed distribution to shareholders. A transaction that provides an economic benefit to a corporation's shareholders can be treated as a dividend for federal income tax purposes even if the transaction has not been identified as a dividend by the Board of Directiors. A constructive dividend need not be issued pro rata to shareholders.

This course is designed to provide practitioners with detailed information on when constructive dividends are imposed, and an analysis of methods to avoid or minimize the imposition of constructive dividends.

Upon completion of the course, the tax professional should be able to:

• State how the tax code and regulations define the term dividend;
• Identify regulations listing constructive dividends;
• Identify various types of transactions that can result in constructive dividends;
• Refer to various court cases in the area; and
• Utilize tax planning strategies to avoid or minimize constructive dividends