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DRDS |
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Observation: Corporations will have less (or no) incentive to earn reorganization boot dividends because-- as extraordinary dividends--the income will give rise to stock basis reductions measured by the DRDs when the dividends are received. Several states have changed provisions on DRDs and interest and intangible expenses paid to related companies. Both DRDs and IRD are included in an estate under the estate tax laws (as either a claim against the estate or assets); when later paid or collected, they are allowed as income tax deductions or required to be included in income. |
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