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.

Aug 9, 2025 · 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), …

2 days ago · Understand Internal Revenue Code (IRC) Section 382, limitation on net operating loss carryforwards and certain built-in losses following ownership change.

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.

Jun 10, 2021 · When an ownership change, as defined in IRC Section 382, occurs, it results in an IRC Section 382 limitation that applies to all NOLs and credits generated prior to the …

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.

Apr 24, 2024 · Considering a new investor or change in ownership? Learn about Section 382 and net operating loss (NOL) before undertaking transactions for informed tax planning.

Sections 382 and 383 together limit the use of net operating losses (NOLs), and certain other tax attributes, by corporations. These provisions apply after a corporation undergoes an …

Jun 9, 2025 · Stock purchases by corporate owners can trigger Section 382 NOL carryforward limits that may go unnoticed for years. Learn how to reduce the risk of inadvertent penalties.

Jan 1, 2024 · --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 …