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- 26 U. S. Code § 382 - Limitation on net operating loss . . .
Except as provided in paragraph (2), if the new loss corporation does not continue the business enterprise of the old loss corporation at all times during the 2-year period beginning on the change date, the section 382 limitation for any post-change year shall be zero
- Credits and NOLs Under Section 382 More Section 382 FAQs . . .
IRC Section 382 measures shareholders’ ownership percentage based on value Companies need to understand the relative value of each class of stock—not just the number of shares—on any given testing date to track the ownership percentages, and potential increases, of respective shareholders
- Understanding Section 382: Net Operating Loss in a . . . - GHJ
WHAT IS THE SECTION 382 LIMITATION? Section 382 imposes a limitation on a company to use its historical NOLs and certain other tax attributes in the event of an ownership change — defined as a 50-percent or greater change in ownership of five-percent shareholders over a rolling three-year period
- Corporate contraction and Sec. 382 - The Tax Adviser
When an ownership change occurs within the meaning of Sec 382, a loss corporation may be limited in its ability to use NOLs and certain tax credits, as well as deduct built-in losses
- Section 382 Limitations and Net Operating Losses in M A
Section 382 Limitations and Net Operating Losses in M A: Full Tutorial to NOLs and How Section 382 Affects Buyers and Sellers in M A Deals with Excel Examples
- Section 382 Limitation: How It Impacts Net Operating Losses
Explore how Section 382 affects net operating losses, focusing on ownership changes, equity measurements, and tax coordination
- A primer of section 382 built-in gains and losses - RSM US
Congress enacted “new” section 382 as part of the Tax Reform Act of 1986 to provide a comprehensive system to prevent trafficking in NOLs 1,2 This code section was designed to make a buyer economically indifferent to acquiring a corporation with or without NOLs
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