constructive dividendsの例文
- The IRS has formally non-acquiesced to the " Rail Joint " doctrine, arguing that what really happens in these situations is a constructive dividend and purchase : The corporation constructively issues a cash dividend to shareholders, who then contribute that cash back to the corporation in exchange for the bonds; the burdened asset is thus the constructively re-contributed cash . " Rail Joint " is nonetheless good law, and has been expanded to encompass other situations where the taxpayer received nothing of value in exchange for the debt, such as when a guarantor of a loan who did not enjoy the benefit of the loan settles it for less than the face amount.
