WebJun 11, 2024 · In change of control stock transactions involving corporations with NOLs, Internal Revenue Code Section 382 imposes a limitation on post-sale utilization of pre-change NOLs and certain other corporate tax attributes (e.g., recognized built-in losses) after an “ownership change.” http://federal.elaws.us/cfr/title26.part1.section1.382-6

Structuring Acquisitive Transactions in Difficult Times

WebFinal Regs. on Section 382 Closing-of-Books Election by Robert W. Wooel • San Francisco Final regulations have been issued under Section 382 (TD 8546) dealing with … WebFeb 1, 1995 · Sec. 382 (b) (3) (A) provides the general rule that taxable income or loss must be allocated ratably to each day in the year of the ownership change. The IRS … task scheduler spring boot

Brian Stelter planning book on Fox News, Dominion lawsuit

Webratably allocating a portion to each day in the tax year. The election under Reg. 1.382-6(b)(3) allows a corporation to allocate income and loss between the periods as if the … WebCLOSING-OF-THE-BOOKS ELECTION UNDER §1.382–6(b) IS HEREBY MADE WITH RESPECT TO THE OWNERSHIP CHANGE OCCURRING ON [INSERT DATE].’’ The election must be made on or before the due date (including exten-sions) of the loss corporation’s income tax return for the change year. WebIf a closing-of-the-books election is made, the S-corporation's taxable year is treated as if it consisted of two separate tax years, the first of which ends on the date of the stockholder's termination. Get full access to this document with Practical Law task scheduler start in cmd