Common use of Distribution of AE&P Clause in Contracts

Distribution of AE&P. Pursuant to paragraph (b)(3)(i) of this section, the portion of the distribution that is sourced from AE&P is equal to the lesser of: The product of the qualified distribution and the AE&P ratio ($100 × 0.5, or $50), and X’s AE&P immediately before the qualified distribution ($25). Therefore, $25 is sourced from AE&P. Pursuant to paragraph (b)(3)(ii) of this section, after the distribution, X’s AE&P is reduced by $25 to $0. Pursuant to paragraph (b)(3)(iii) of this section, $25 of the distribution is characterized as a dividend.

Distribution of AE&P. Pursuant to paragraph (b)(3)(i) of this section, the portion of the distribution that is sourced from AE&P is equal to the lesser of: The product of the qualified distribution and the AE&P ratio ($100 200 × 0.5, or $50100), and X’s AE&P immediately imme- diately before the qualified distribution distribu- tion ($2550). Therefore, $25 50 is sourced from AE&P. Pursuant to paragraph (b)(3)(ii) of this section, after the distributiondis- tribution, X’s AE&P is reduced by $25 50 to $0. Pursuant to paragraph (b)(3)(iii) of this section, the $25 of the 50 distribution is characterized as a dividend.

Distribution of AE&P. Pursuant to paragraph (b)(3)(i) of this section, the portion of the distribution that is sourced from AE&P is equal to the lesser of: The the product of the qualified distribution and the AE&P ratio ($100 500 × 0.50.75, or $50375), and X’s AE&P immediately imme- diately before the qualified distribution distribu- tion ($25580). Therefore, $25 375 is sourced from AE&P. Pursuant to paragraph (b)(3)(ii) of this section, after the distributiondis- tribution, X’s AE&P is reduced by $25 375 to $0205. Pursuant to paragraph (b)(3)(iii) of this section, the $25 of the distribution 375 dis- tribution is characterized as a dividenddivi- dend.

Distribution of AE&P. Pursuant to paragraph (b)(3)(i) of this section, the portion of the distribution that is sourced from AE&P is equal to the lesser of: The product of the qualified distribution and the AE&P ratio ($100 × 0.5, or $50), and X’s AE&P immediately before the qualified distribution ($25100). Therefore, $25 50 is sourced from AE&P. Pursuant to paragraph (b)(3)(ii) of this section, after the distribution, X’s AE&P is reduced by $25 50 to $050. Pursuant Pursu- ant to paragraph (b)(3)(iii) of this sectionsec- tion, the $25 of the 50 distribution is characterized character- ized as a dividend.

Distribution of AE&P. Pursuant to paragraph (b)(3)(i) of this section, the portion of the distribution that is sourced from AE&P is equal to the lesser of: The product of the qualified distribution and the AE&P ratio ($100 150 × 0.50.33, or $50), and X’s AE&P immediately imme- diately before the qualified distribution distribu- tion ($2570). Therefore, $25 50 is sourced from AE&P. Pursuant to paragraph (b)(3)(ii) of this section, after the distributiondis- tribution, X’s AE&P is reduced by $25 50 to $020. Pursuant to paragraph (b)(3)(iii) of this section, the $25 of the 50 distribution is characterized as a dividend. (3) Example 3: Limitation on amount characterized as AAA—(i)