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
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. 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
Navigate the Challenges of Section 382 - Moss Adams There are many complexities regarding the application of Section 382 and resulting limitations on the use of NOLs and other tax attributes, including the application of Section 382 for federal versus state income or franchise tax purposes