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. 26 U.S. Code § 382 - Limitation on net operating loss carryforwards and ...
Section 382 of the Internal Revenue Code caps how much of a corporation’s pre-change net operating losses can offset taxable income each year after a significant shift in ownership. 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 ownership change date that can be used to offset taxable income incurred after the ownership change date. Credits and NOLs under section 382 & more section 382 FAQs | Baker Tilly Understand Internal Revenue Code (IRC) Section 382, limitation on net operating loss carryforwards and certain built-in losses following ownership change. 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.
382 9th ave, The section 382 limitation for any post-change year that is less than 365 days is the amount that bears the same ratio to the section 382 limitation determined under section 382 (b) (1) as the number of days in the post-change year bears to 365.
