Any loss corporation that has an ownership change is subject to Section 382. A loss corporation is any corporation that is entitled to use certain tax attributes, such as net operating loss carryforwards, capital loss carryovers, carryovers of excess foreign taxes, carryforwards of general business credits, carryovers of minimum tax credits, or
net unrealized built-in losses.
See Treas. Reg. § 1.382-2(a)(1)(A); IRC § 382(k)(1).