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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
Credits and NOLs Under Section 382 More Section 382 FAQs | Moss Adams The bottom line is, if your company is accumulating NOLs and credits, you need to consider IRC Section 382—whether or not your company has undergone a clear ownership change This article addresses the following questions and topics: What is an IRC Section 382 limitation? What is an IRC Section 382 study? Why perform an IRC Section 382 study?
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 Section 382 of the Internal Revenue Code plays a critical role in determining how companies can utilize net operating losses (NOLs) following significant changes in ownership
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
Net Operating Losses and Other Tax Attributes — Sections 381, 382, 383 . . . Section 382 limits the income against which the Net Operating Loss Carryovers (and Net Operating Losses in the year of the change) can be deducted Section 383 applies similar limitations to a corporation's income (or tax liability) against which tax attributes (other than Net Operating Losses) can be applied
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