In some cases, state regulators can restrict banks from paying dividends if their accumulated earnings do not meet a certain threshold.
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Second, if you accumulate too much in earnings in a C corp, you could be hit with the accumulated earnings tax or the personal holding company tax.
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Regardless of that, earnings, accumulated or otherwise, do not perfectly correlate with cash flow so it strikes me that the comment is mixing oranges and apple sauce.
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Dividends are typically paid out of earnings, either current or accumulated.
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