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. the long-term tax-exempt rate.
Credits and NOLs Under Section 382 & More Section 382 FAQs
Jun 10, 2021 · IRC Section 382 generally measures an ownership change by looking at cumulative increases over a three-year period. This means an ownership change can be triggered by rounds of financing that occur during a three-year period.
Section 382 Limitation: How It Impacts Net Operating Losses
Jan 29, 2025 · 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.
Understanding Section 382: Net Operating Loss in a Transaction
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.
Corporate contraction and Sec. 382 - The Tax Adviser
May 1, 2017 · 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 primer of section 382 built-in gains and losses - RSM US
Feb 28, 2022 · Congress enacted “new” section 382 as part of the Tax Reform Act of 1986 to provide a comprehensive system to prevent trafficking in NOLs.1,2 This code section was designed to make a buyer economically indifferent to acquiring a …
Net Operating Loss Carryforwards (Section 382) - EisnerAmper
To maximize NOL tax savings, it is critical for companies to work with a business advisory firm that understands the complexities of Internal Revenue Code 382. EisnerAmper can effectively conduct or update companies’ Section 382 studies.
382 - U.S. Code Title 26. Internal Revenue Code - FindLaw
Jan 1, 2024 · Internal Revenue Code § 382. Limitation on net operating loss carryforwards and certain built-in losses following ownership change Current as of January 01, 2024 | Updated by FindLaw Staff
Updates to Sec. 382 NUBIG and NUBIL safe harbors - The Tax …
Aug 1, 2018 · With the increased use of stock acquisitions, buyers must correctly apply the Sec. 382 limitations, including the additional analysis required by Sec. 382(h) to determine the impact of NUBIG and NUBIL.
Section 382: Complexity and Simplicity at Its Finest
Jan 10, 2012 · Section 382 imposes an annual limitation on the amount of taxable income that may be offset by net operating loss ("NOL") carryforwards to the extent a loss corporation experiences an ownership change.
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