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Pepper Hamilton LLP Tax Update: New Chief Counsel Advice on Coordinated Acquisitions for Section 382 Purposes Raises Concerns

By Todd B. Reinstein , Partner, Pepper Hamilton LLP Section 382 limits a loss corporation's ability to use its tax net operating loss (NOLs) carryforward following an "ownership change."[1] An ownership change is triggered if one or more "5-percent shareholders" of the loss...

Pepper Hamilton LLP Tax Update: New Chief Counsel Advice on Coordinated Acquisitions for Section 382 Purposes Raises Concerns

By Todd B. Reinstein , Partner, Pepper Hamilton LLP Section 382 limits a loss corporation's ability to use its tax net operating loss (NOLs) carryforward following an "ownership change."[1] An ownership change is triggered if one or more "5-percent shareholders" of the loss...