Section 382 Ownership Change – July 2017

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When a company has a Section 382 ownership change, its pre-change NOLs are subject to an annual limitation — the Section 382 Limitation. The Section 382 Limitation is calculated by multiplying the value of the old loss corporation by the applicable long-term tax-exempt rate for the month of the ownership change.

For July 2017, the applicable long-term tax-exempt rate is 2.04%.Long-Term Tax-Exempt Rate - March 2017

The long-term tax-exempt rate is the highest of the adjusted federal long-term rates in effect for any month in the 3-calendar-month period ending with the calendar month in which the change date occurs.

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