I had people spit on me, throw things at me and want to physically fight me â people who had never met me or talked to me. In the age of social media, this is what I get:  @kato_kaelin why don't U just die, loser. Ur worthless.. Never has a man done so little to be recognized by so many.
Full or partial cash repayment of the debt by the corporation reduces the shareholder's loan basis. (Repayment with property other than cash is beyond the scope of this item.) If the debt basis has previously been reduced to zero, all the subsequent repayment is treated as taxable income to the shareholder.
If a U.S. shareholder sells CFC stock, recognized gain will be included in taxpayerâs gross income as an ordinary dividend to the extent of the foreign corporationâs earnings and profits allocable to the stock (IRC Sec. 1248). Any gain exceeding the CFCâs earnings and profits is treated as capital gain. CFCâs Subpart F income is limited for any tax year to its total earnings and profits for that year. The income is treated as a deemed dividend. A foreign corporation is a CFC if more than 50 percent of its total voting power or value is owned by U.S. shareholders (IRC Sec. 957).