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
Understanding Section 382: Net Operating Loss in a Transaction - 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 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
What Is IRC 382 and How Does It Impact Net Operating Losses? Explore how IRC 382 affects net operating losses, focusing on ownership changes, shareholder grouping, and tax implications IRC 382 plays a significant role in the tax landscape, particularly for corporations with net operating losses (NOLs)
A Practical Look at Section 382 - Troutman Section 382 will be important if the transaction is a stock acquisition (with no 338 election if taxable) or a qualifying tax-free reorganization (Section 381 applies), or any transaction in which equity is issued and one or more parties is a loss corporation
382 - U. S. Code Title 26. Internal Revenue Code - FindLaw Limitation on net operating loss carryforwards and certain built-in losses following ownership change (a) General rule --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 (b)Section 382 limitation
Section 382 - Net Operating Loss Carryforward Rules and Regulations IRC Section 382 ("S382") limits tax deductions, primarily for net operating losses, following a corporation's ownership change It prevents "double dipping" and ensures fair tax treatment after ownership changes