26 U. S. Code § 382 - LII Legal Information Institute The amount of the taxable income of any new loss corporation for any post-change year which may be offset by pre-change losses shall not exceed the section 382 limitation for such year
What Is Section 382 and How Does It Limit NOLs? - LegalClarity Section 382 of the Internal Revenue Code (IRC) is a tax provision designed to prevent the misuse of a company’s tax attributes, particularly Net Operating Losses (NOLs), after a change in its ownership
Credits and NOLs Under Section 382 More Section 382 FAQs - Moss Adams When an ownership change, as defined in IRC Section 382, occurs, it results in an IRC Section 382 limitation that applies to all NOLs and credits generated prior to the ownership change date that can be used to offset taxable income incurred after the ownership change date
Section 382 Limitations and Net Operating Losses in M A In this lesson, you’ll learn how the Section 382 limitations on Net Operating Loss (NOL) usage affect M A deals and determine the transaction structures that Acquirers are likely to use
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
§382. Limitation on net operating loss carryforwards and . . . - House If the section 382 limitation for any post-change year exceeds the taxable income of the new loss corporation for such year which was offset by pre-change losses, the section 382 limitation for the next post-change year shall be increased by the amount of such excess