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 USC 382: Limitation on net operating loss carryforwards and certain built-in losses following ownership change Text contains those laws in effect on January 11, 2026

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), after a change in its …

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.

Dec 8, 2025 · Understand Internal Revenue Code (IRC) Section 382, limitation on net operating loss carryforwards and certain built-in losses following ownership change.

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 ownership …

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.

Except as otherwise provided, this section applies to a loss corporation that has an ownership change to which section 382 (a), as amended by the Tax Reform Act of 1986, applies.

Aug 27, 2025 · IRC section 382 net operating loss limitation rules represent one of the most complex areas of federal tax law, governing how corporations can utilize net operating losses (NOLs) …

Many companies have existing NOL/credit carryforwards or are experiencing current losses. To maximize NOL tax savings and manage expectations, it is critical for companies to work with a …