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
§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
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
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
382 - U. S. Code Title 26. Internal Revenue Code - FindLaw --If the old loss corporation has a net unrealized built-in gain, the section 382 limitation for any recognition period taxable year shall be increased by the recognized built-in gains for such taxable year
IRC Section 382 Net Operating Loss Limitation Rules Guide IRC section 382 net operating loss limitation rules represent one of the most complex areas of federal tax law, governing how corporations can utilize net operating losses (NOLs) following significant ownership changes
eCFR :: 26 CFR 1. 382-5 -- Section 382 limitation. The section 382 limitation for any post-change year that is less than 365 days is the amount that bears the same ratio to the section 382 limitation determined under section 382 (b) (1) as the number of days in the post-change year bears to 365