Are the earnings of the EOT taxable?
In a C corporation, the trust would normally not have any earnings to be taxed. Dividends would be paid directly to the employees. In an S corporation, earnings attributable to the trust are taxable at the highest personal income tax rate. For that reason, employee ownership trust companies either are or convert to C status.
For more details, see Using an Employee Ownership Trust for Business Transition.
Link to this FAQ Topic: Employee Ownership Trusts (EOTs)