Avoiding Dividend Treatment on Corp. Withdrawals

Arend, Laukhuf & Stoller, Inc.

Even though no dividend has been declared, IRS has the ability to treat withdrawals of cash from the corporation, and other transactions, as dividends, if they aren't handled properly. Although dividends are now taxable to noncorporate shareholders at capital gains rates, the tax can be avoided with a little planning. A Tax Court case demonstrates what can happen when a shareholder isn't careful and treats a corporation he or she controls as though it were, in effect, a personal bank account.

In that case, a husband and wife owned the corporation. The husband, John, ran the corporation, and dealt with it very informally. He took money out as needed for personal expenses, and received a $100 check along with each weekly paycheck. John and the corporation accounted for these withdrawals as “shareholder advances,” and both John and the corporation showed these advances as loans on financial statements that were given to third parties. At the end of every year, part of the outstanding balance of the shareholder advances account was repaid by crediting John's year-end bonuses against it.

Nevertheless, on audit IRS determined that the shareholder advances weren't true loans, and treated them as dividends. The Tax Court agreed with IRS. John argued that the casual way in which he and the corporation handled the advances shouldn't be held against him because all of his dealings with the corporation were informal. The court wasn't impressed by this or by John's other arguments, and wanted proof that John intended to repay the advances, and that the corporation intended to require repayment.

There are about a dozen factors that the courts look at to decide if a shareholder withdrawal is a loan or a dividend. Most of these are within your control. One important factor, for example, is whether there is a written promissory note. It isn't necessary that each of the factors point to a loan, but taken together they must be sufficient to establish that the withdrawal is not a dividend.

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