Final answer:
Distributions from a corporation to its shareholders are first applied against current Earnings and Profits (E&P), and then against accumulated E&P. This affects the tax consequences for the shareholder receiving the distribution.
Step-by-step explanation:
The student is asking about the order in which distributions come out of Earnings and Profits (E&P) for a corporation. The question pertains to the tax treatment of distributions made by a corporation to its shareholders. These distributions are considered first to come out of the corporation's current E&P, and then, any excess is applied against accumulated E&P. This ordering is important because it affects the tax implications for the shareholder receiving the distribution.
Current E&P refers to the net income of a corporation for the current year, while accumulated E&P refers to the net income from previous years that has not been distributed to shareholders. When a corporation issues a distribution, the IRS assumes it comes from the current E&P first. Once the current E&P has been exhausted, any remaining distribution is deducted from the accumulated E&P.