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  • 26 U. S. Code § 382 - LII Legal Information Institute
    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
  • Corporate contraction and Sec. 382 - The Tax Adviser
    Corporations with federal net operating losses (NOLs) or built-in losses need to be cognizant of the potential limitations imposed by Sec 382 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
  • A Practical Look at Section 382 - Troutman
    Overview of Section 382 Purpose of Section 382: • Limits ability of a corporation to offset future income using NOLs generated prior to a “change in ownership” and certain built-in losses recognized post -change Policy: • Enacted to prevent “trafficking” in NOLs • Is designed to prevent abuses involving the acquisition of loss
  • 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
  • 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
  • A primer of section 382 built-in gains and losses - RSM US
    While section 382(m) instructs the Treasury to prescribe regulations to carry out the purposes of sections 382 and 383, no final regulation have been issued for section 382(h), relating to the calculation of NUBIG NUBIL and RBIG RBIL
  • Understanding Section 382: Net Operating Loss in a Transaction
    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
  • Section 382 Limitations and Net Operating Losses in M A
    Section 382 Limitations and Net Operating Losses in M A: Full Tutorial to NOLs and How Section 382 Affects Buyers and Sellers in M A Deals with Excel Examples
  • Credits and NOLs Under Section 382 More Section 382 FAQs - Moss Adams
    IRC Section 382 measures shareholders’ ownership percentage based on value Companies need to understand the relative value of each class of stock—not just the number of shares—on any given testing date to track the ownership percentages, and potential increases, of respective shareholders
  • 382 - Wikipedia
    Year 382 was a common year starting on Saturday of the Julian calendar At the time, it was known as the Year of the Consulship of Antonius and Syagrius (or, less frequently, year 1135 Ab urbe condita )





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