IRS Unveils Rules on Treatment of Smaller Shareholders' NOLs

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IRS unveils new guidance (REG-149625-10) on ownership changes under tax code Section 382 that practitioners say will simplify things for smaller shareholders and lead to fewer changes that would trigger limitations on the use of losses in reorganizations. The government says it is taking an approach to target only cases in which abuse could arise, which practitioners say is a sensible solution for shareholders who may not have the resources to trace and track all of their ownership changes. “It's a reasonable position and I think they've thought about it for a while,” Mark Silverman, a partner with Steptoe & Johnson LLP in Washington, D.C., tells BNA.