Relatively recent revisions to the Code have modified the tax treatment of dividends

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Relatively recent revisions to the Code have modified the tax treatment of dividends. Put your Internet research

skills to use and tell me about these changes and their consequences.

In particular, tell me
(1) what dividends are, as defined by the Code;
(2) what the recent changes effectively do (and how it was different from the prior approach to the taxation of dividends); and
(3) what the changes sought to achieve (in other words, why was the change made?).

 
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Emerald Corporation, a calendar year C corporation, was formed and began operations on July 1, 2014.

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Emerald Corporation, a calendar year C corporation, was formed and began operations on July 1, 2014. The

following expenses were incurred during the first tax year (July 1 through December 31, 2014) of operations:

Expenses of temporary directors and of organizational meetings $9,000
Fee paid to the state of incorporation $1,000
Accounting services incident to organization $2,500
Legal services for drafting the corporate charter and bylaws $3,500
Expenses incident to the printing and sale of stock certificates $4,000

Assuming a Section 248 election, what is the Emerald’s deduction for organizational expenditures for 2014?

 
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$60,000 $75,000

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$60,000$75,000

 
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$50,000 of dividend income and $15,000 recovery of capital.

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$50,000 of dividend income and $15,000 recovery of capital.$60,000 of dividend income and

$5,000 recovery of capital.

$65,000 of dividend income.

 
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