Section 382 ownership change – September 2017
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 September 2017, the long-term tax-exempt rate is 1.93%. 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.
Additionally, the adjusted federal long-term rate for the current month is 1.93%.