Which of the Following Statements, If Any, Is Characteristic of Constructive

Which of the following statements, if any, is characteristic of constructive dividends?

A) They must be available to the shareholders on a pro rata basis.
B) They can occur even if the corporation has no earnings and profits.
C) They must be formally declared and paid (i.e., declaration date, record date, payment date) .
D) They are not deductible by the corporation.
E) None of the above.