Dahl Corp. was organized and commenced operations in Year 0. At December 31, Year 5, Dahl had accumulated earnings and profits of $9,000 before dividend declaration and distribution. On DecemÂber 31, Year 5, Dahl distributed cash of $9,000 and a vacant parcel of land to Green, Dahl’s only stockholder. At the date of distribution, the land had a basis of $5,000 and a fair market value of $40,000. What was Green’s taxable dividend income in Year 5 from these distributions?
You answered A. The correct answer is C.
When a corporation distributes both cash and property dividends, the corporation must recognize a gain on the appreciated property distributed as a dividend. The recognized gain comes from treating the property “as if” it were sold at fair market value. In this problem, the recognized gain will be $35,000, which is the fair market value (amount realized) of $40,000 less the adjusted basis of $5,000.
The corporation’s earnings and profits are increased by the recognized gain on the property dividend. So, now the earnings and profits for Dahl Corporation will be $44,000, which is the $9,000 plus the recognized gain of $35,000.
The shareholder, Green, will have maximum dividend income from the cash received of $9,000 plus the fair market value of the property received of $40,000. However, the dividend income that is taxable to Green cannot exceed the earnings and profits of Dahl Corporation, which is $44,000.