The U.S. IRS has released an international practice unit, Taxability of Distributions Not from Accumulated Earnings & Profits.
The practice unit addresses the taxability of distributions from an S corporation that either (1) does not have accumulated earnings and profits (AE&P), or (2) makes distributions from sources other than AE&P; that is, nondividend distributions made from the accumulated adjustments account (AAA), other adjustments account (OAA), or a shareholder-level p…