Corporate purchases and sales require consideration of various corporate attributes. One of the most important is the available use of a target corporations net operating losses (NOLs) by the purchaser. Internal Revenue Code section 382 provides detailed rules regarding when the NOL is available and what limitations may apply.
Learning Objectives
- Upon completion of this course, you'll be able to:
- Identify key components and applications of IRC § 382, including limitations on net operating loss usage following an ownership change.
- Examine calculation methods, coordination with the applicable federal rate, and the implications of reporting rules and bankruptcy scenarios.
- Evaluate how IRC § 382 applies to S corporations through practical workshop examples and real-world considerations.
Major Topics
- This discussion will include:
- General discussion of IRC § 382
- Calculation of § 382 limitations
- Coordination of the applicable federal rate
- Consideration of reporting rules and procedures
- Workshop examples will be presented
- Bankruptcy considerations
- S corp application
