Final Section 382 Rules Retain Exception for Small Shareholders

The guidance remains taxpayer-friendly and offers simplicity to smaller taxpayers whose transactions shouldn't trigger rules preventing the use of losses under Section 382, practitioners told Bloomberg BNA in interviews Oct. 21.
Section 382 limits a corporation's ability to carry forward net operating losses and use other tax benefits following a change in ownership. The rules deal with when corporations must apply the so-called segregation rules to determine whether an ownership change has occurred. They allow more generous use of losses to corporations that meet certain tests.
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