"Distributions" implies that we are concerned with the tax problems of the stockholder rather than those of the corporation. And while one corporation may be the stockholder of another, my emphasis will be primarily upon stockholders who are individuals, including, of course, trusts and estates who are taxed as individuals.
William M. Emery,
TAXING DISTRIBUTIONS PURSUANT TO CORPORATE REORGANIZATIONS,
Mich. L. Rev.
Available at: https://repository.law.umich.edu/mlr/vol50/iss4/4