Contributing editor Robert Willens, founder and principal of Robert Willens LLC, writes a weekly tax column for CFO.com.
Footnotes
1 See Sec. 172(b)(1)(H).
2 An applicable corporation is a C corporation that acquires stock, or the stock of which is acquired, in a major stock acquisition or a C corporation making distributions with respect to, or redeeming, its stock in connection with an excess distribution.
3 The taxable year in which the CERT occurs and each of the two succeeding years.
4 As expanded by Sec. 172(b)(1)(H).
5 The amount determined under the aggregate distribution and 150% of the average distribution shall be reduced by the aggregate amount of stock issued by the corporation during the applicable period in exchange for money or property other than stock of the corporation.
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