ADVANCED FEDERAL TAXATION DISCUSSION QUESTION

"Taxation of Shareholder Benefits" Please respond to the following:

·         If a company experiences a complete loss of an office building as a result of a fire and receives a $2 million recovery payment from the insurance company:

·          

o    Explain the tax consequences if the company decides not to rebuild.

o    Identify the tax consequences if the company distributes the $2 million to its two (2) shareholders, assuming that no stock was exchanged in return.

o    Under what conditions will the distribution meet the requirements to be treated as a partial liquidation and not a dividend?