Nonliquidating distributions, including but not limited to:

  • Assisting in calculating earnings and profits;
  • Advising on dividend and qualified dividend treatment;
  • Advising on ways to minimize the dividend treatment under 301;
  • Advising on distributions of cash and property and the 311 gain and resulting 301 dividend;
  • Advising on constructive dividends and resulting unexpected tax results;
  • Dividends received deduction and advising on holding period; and
  • Extraordinary dividends and basis reduction.