Q re: S Corp paying out all AE&P

Q re: S Corp paying out all AE&P

We converted from C to S and now wish to pay out all AE&P. Problem is that we don't have the cash reserves. What we'd like to do is get enough cash into the shareholders hands to cover the tax on the AE&P.

Let's say we have an AE&P of 1,000,000. Can we deem that 1,000,000 was distributed and then distribute 250,000 in cash or must we actually distribute 1,000,000 in cash and if we do that can the shareholders then loan 750,000 back to the Holding Co.?

Thx

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