Skip navigation.
Home
Get & Give Tax Help for Small Businesses

Equalizing AAA Accounts through Distributions

An S-Corp with three initial shareholders has been operating for a number of years. During 2008, these shareholders sold equal portions of their holdings to two outside investors.

2008 had heavy losses in the first two quarters. The latter portion of the year turned out to be quite profitable.

Since the shareholders sold the shares prior to realizing the profits of the second half of the year, the shareholders now have unequal AAA balances. The S-corp was never a C-corp (no e&p). The shareholders now wish to even the AAA balances so that each partner has the same basis going forward.

Is there any mechanism that would allow the shareholders to allocate AAA or receive uneven distributions in effort to make this happen?