When S corporation distributions are used to repay an ESOP debt in an S corporation, can they be paid on both allocated and unallocated shares?
Yes. As a result of tax law changes passed in 2004, ESOPs in S corporations can now use distributions on allocated and unallocated shares to repay an ESOP loan.
For details on S corporation ESOPs, see S Corporation ESOPs.
Link to this FAQ Topic: S Corporation ESOPs