Which of the Following S Corporations Would Be Subject to the Excess

Which of the following S corporations would be subject to the excess net passive income tax?

A) An S corporation that never operated as a C corporation.
B) An S corporation that has previously distributed all earnings and profits from prior C corporation years.
C) An S corporation with no earnings and profits from prior C corporation years and with passive investment income that exceeds 30% of its gross receipts.
D) An S corporation with $2,000 of earnings and profits from prior C corporation years and with passive investment income that equals 22% of its gross receipts.
E) None of these