Jack Townsend has an excellent post today (all of his posts are excellent) about C corporation constructive dividends. In United States v. Ellefsen, ___ F.3d ___, 2011 U.S. App. LEXIS 18684 (8th Cir. 2011), the appeals court addressed the issue of whether the IRS properly reclassified payments made by a C corporation to a trust, of which… Continue reading Constructive Dividends and the Substance Over Form Doctrine