SECTION 382 BLOG
Is every testing period 3 years?
What is the long-term tax-exempt rate?
Are certain statutory adjustments to the initial Section 382 Limitation required?
If an ownership change occurs mid-year, must the Section 382 Limitation be pro-rated?
Is there an exception to the ratable allocation method?
How is a closing-of-the-books election made?
If the loss corporation’s income is less than the Section 382 Limitation, will the Section 382 Limitation be adjusted?
If a loss corporation has a subsequent ownership change, how will this affect the Section382 Limitation for the first ownership change?
How does a loss corporation determine if it has NUBIL at the time of the ownership change?
What types of transactions could cause a Section 382 “ownership change”?
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