§302 Corporate Redemptions: Capital Gain vs. Dividend

4 Sale Tests • §318 Attribution Kills Many Redemptions • Complete Termination Waiver • Partial Liquidation
IRC §302IRC §318IRC §301
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When a corporation buys back its own stock from a shareholder, the tax consequences depend entirely on whether the redemption qualifies as a "sale or exchange" - producing capital gain or loss - or fails to qualify, in which case the entire redemption proceeds are treated as a §301 distribution (a dividend to the extent of earnings and profits, then return of basis, then capital gain). For a high-income shareholder, the difference between a 20% capital gain and a 37% ordinary income dividend on the same transaction can be the most important tax question in the deal. The §318 constructive ownership attribution rules make many redemptions that appear to qualify as exchanges into dividends in disguise.

The Four §302(b) Tests for Sale Treatment

§302(b)(1) - Not essentially equivalent to a dividend: A facts-and-circumstances test. The redemption must produce a meaningful reduction in the shareholder's proportionate interest. Difficult to satisfy without significant percentage reduction.

§302(b)(2) - Substantially disproportionate: After the redemption, the shareholder owns less than 80% of the percentage owned before, and owns less than 50% of total combined voting power. Safe harbor with clear thresholds.

§302(b)(3) - Complete termination: The corporation redeems all of the shareholder's stock and the shareholder retains no interest in the corporation (other than as a creditor). The most reliable path to sale treatment.

§302(b)(4) - Partial liquidation: Distribution in partial liquidation of the corporation - requires a genuine contraction of the corporate business. Tested at the corporate level, not the shareholder level.

§318 Constructive Ownership: The Rule That Destroys Most Redemptions

The §318 attribution rules attribute stock ownership between family members, between a shareholder and entities the shareholder controls, and between an entity and its owners. For redemption purposes: (1) a shareholder is deemed to own stock owned by their spouse, children, grandchildren, and parents; (2) a 50%+ partner in a partnership is deemed to own the partnership's stock; (3) a 50%+ shareholder in a corporation is deemed to own the corporation's stock; and (4) a beneficiary of a trust is deemed to own the trust's stock.

§318 attribution turns many family business redemptions into dividends. A father who owns 60% of a corporation sells all of his shares back to the corporation. Without attribution, this is a complete termination under §302(b)(3) - capital gain treatment. But if the father's son owns the remaining 40%, the father constructively owns 100% after the redemption through attribution from his son. No meaningful reduction in interest occurred from the corporation's perspective. The entire redemption is a dividend. This result surprises most clients and advisors who do not run the attribution analysis before structuring the transaction.

The Complete Termination Waiver: Escaping Family Attribution

IRC §302(c)(2) provides an escape from family attribution in complete termination redemptions. If the redeemed shareholder: (1) retains no interest in the corporation (as officer, director, employee, or otherwise) other than as a creditor; (2) does not acquire any prohibited interest within 10 years; and (3) files an agreement with the IRS to notify the IRS if a prohibited interest is acquired within 10 years - then family attribution is waived and the complete termination qualifies as a sale. The waiver is the standard planning tool for family business buyouts where the departing shareholder is a parent or grandparent of continuing shareholders.

§301 Distribution: The Default Result

A redemption that fails all four §302(b) tests is treated as a §301 distribution - the same as a regular dividend. The distribution is: (1) ordinary income (dividend) to the extent of the corporation's current and accumulated earnings and profits (E&P); (2) tax-free return of basis to the extent of the shareholder's basis in the redeemed stock; (3) capital gain for any excess. The shareholder's basis in the redeemed shares is not lost - under the IRS's position in Rev. Rul. 70-531, the basis shifts to the shareholder's remaining shares (if any) or to related parties whose shares caused the attribution.

Authority: IRC §302 (redemptions treated as exchanges - four tests for capital gain treatment; §302(b)(1) not essentially equivalent to dividend; §302(b)(2) substantially disproportionate; §302(b)(3) complete termination; §302(b)(4) partial liquidation); IRC §302(c)(2) (complete termination waiver of family attribution - requirements: no retained interest, 10-year no-reacquisition agreement, IRS notification agreement; eliminates §318(a)(1) family attribution for complete termination purposes only); IRC §301 (distributions of property - treatment as dividend to extent of E&P, then return of basis, then capital gain; applies to redemptions failing all §302(b) tests); IRC §318 (constructive ownership of stock - family attribution: spouse, children, grandchildren, parents; entity-to-owner and owner-to-entity attribution; option attribution; operating rules for applying multiple attribution steps); IRC §318(a)(1) (family attribution - shareholder deemed to own stock owned by spouse, children, grandchildren, parents; siblings excluded from family attribution); Treas. Reg. §1.302-2 (not essentially equivalent to dividend standard - meaningful reduction in proportionate interest required; Maclin v. Commissioner standard); Rev. Rul. 75-502 (substantially disproportionate test - both 80% and 50% tests must be met immediately after redemption); Rev. Rul. 70-531 (basis of redeemed shares shifts to remaining shareholder or related party whose attribution caused dividend treatment; basis not lost on failed redemption); IRC §303 (redemptions to pay estate taxes - special redemption provision allowing capital gain treatment for stock included in decedent's estate to cover §2053 expenses and estate taxes).
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