26 U.S. Code § 382 - Limitation on net operating loss carryforwards and certain built-in losses following ownership change
The amount of the taxable income of any new loss corporation for any post-change year which may be offset by pre-change losses shall not exceed the section 382 limitation for such year.
If the section 382 limitation for any post-change year exceeds the taxable income of the new loss corporation for such year which was offset by pre-change losses, the section 382 limitation for the next post-change year shall be increased by the amount of such excess.
Subsection (a) shall not apply to the portion of the taxable income for such year which is allocable to the period in such year on or before the change date. Except as provided in subsection (h)(5) and in regulations, taxable income shall be allocated ratably to each day in the year.
Except as provided in paragraph (2), if the new loss corporation does not continue the business enterprise of the old loss corporation at all times during the 2-year period beginning on the change date, the section 382 limitation for any post-change year shall be zero.
The term “post-change year” means any taxable year ending after the change date.
The term “pre-change loss” shall include any carryover of disallowed interest described in section 163(j)(2) under rules similar to the rules of paragraph (1).
Except as otherwise provided in this subsection, the value of the old loss corporation is the value of the stock of such corporation (including any stock described in section 1504(a)(4)) immediately before the ownership change.
If a redemption or other corporate contraction occurs in connection with an ownership change, the value under paragraph (1) shall be determined after taking such redemption or other corporate contraction into account.
Except as otherwise provided in regulations, in determining the value of any old loss corporation which is a foreign corporation, there shall be taken into account only items treated as connected with the conduct of a trade or business in the United States.
The long-term tax-exempt rate shall be 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.
To the extent provided in regulations, the term “equity structure shift” includes taxable reorganization-type transactions, public offerings, and similar transactions.
Except as provided in subparagraphs (B)(i) and (C), in determining whether an ownership change has occurred, all stock owned by shareholders of a corporation who are not 5-percent shareholders of such corporation shall be treated as stock owned by 1 5-percent shareholder of such corporation.
Subparagraph (A) shall be applied separately with respect to each group of shareholders (immediately before such equity structure shift) of each corporation which was a party to the reorganization involved in such equity structure shift.
Unless a different proportion is established, acquisitions of stock after such equity structure shift shall be treated as being made proportionately from all shareholders immediately before such acquisition.
Except as provided in regulations, rules similar to the rules of subparagraph (B) shall apply in determining whether there has been an owner shift involving a 5-percent shareholder and whether such shift (or subsequent transaction) results in an ownership change.
If the old loss corporation has a net unrealized built-in gain, the section 382 limitation for any recognition period taxable year shall be increased by the recognized built-in gains for such taxable year.
If the old loss corporation has a net unrealized built-in loss, the recognized built-in loss for any recognition period taxable year shall be subject to limitation under this section in the same manner as if such loss were a pre-change loss.
If a redemption or other corporate contraction occurs in connection with an ownership change, to the extent provided in regulations, determinations under clause (i) shall be made after taking such redemption or other corporate contraction into account.
Any item of income which is properly taken into account during the recognition period but which is attributable to periods before the change date shall be treated as a recognized built-in gain for the taxable year in which it is properly taken into account.
Any amount which is allowable as a deduction during the recognition period (determined without regard to any carryover) but which is attributable to periods before the change date shall be treated as a recognized built-in loss for the taxable year for which it is allowable as a deduction.
The amount of the net unrealized built-in gain or loss shall be properly adjusted for amounts which would be treated as recognized built-in gains or losses under this paragraph if such amounts were properly taken into account (or allowable as a deduction) during the recognition period.
The term “recognition period” means, with respect to any ownership change, the 5-year period beginning on the change date.
The term “recognition period taxable year” means any taxable year any portion of which is in the recognition period.
If 80 percent or more in value of the stock of a corporation is acquired in 1 transaction (or in a series of related transactions during any 12-month period), for purposes of determining the net unrealized built-in loss, the fair market value of the assets of such corporation shall not exceed the grossed up amount paid for such stock properly adjusted for indebtedness of the corporation and other relevant items.
The Secretary shall prescribe such regulations as may be necessary to carry out the purposes of this subsection where property held on the change date was acquired (or is subsequently transferred) in a transaction where gain or loss is not recognized (in whole or in part).
Except as otherwise provided in this section, the testing period is the 3-year period ending on the day of any owner shift involving a 5-percent shareholder or equity structure shift.
If there has been an ownership change under this section, the testing period for determining whether a 2nd ownership change has occurred shall not begin before the 1st day following the change date for such earlier ownership change.
The testing period shall not begin before the earlier of the 1st day of the 1st taxable year from which there is a carryforward of a loss or of an excess credit to the 1st post-change year or the taxable year in which the transaction being tested occurs. Except as provided in regulations, this paragraph shall not apply to any loss corporation which has a net unrealized built-in loss (determined after application of subsection (h)(3)(B)).
The term “loss corporation” means a corporation entitled to use a net operating loss carryover or having a net operating loss for the taxable year in which the ownership change occurs. Such term shall include any corporation entitled to use a carryforward of disallowed interest described in section 381(c)(20). Except to the extent provided in regulations, such term includes any corporation with a net unrealized built-in loss.
The term “new loss corporation” means a corporation which (after an ownership change) is a loss corporation. Nothing in this section shall be treated as implying that the same corporation may not be both the old loss corporation and the new loss corporation.
Taxable income shall be computed with the modifications set forth in section 172(d).
The term “5-percent shareholder” means any person holding 5 percent or more of the stock of the corporation at any time during the testing period.
Any capital contribution received by an old loss corporation as part of a plan a principal purpose of which is to avoid or increase any limitation under this section shall not be taken into account for purposes of this section.
For purposes of subparagraph (A), any capital contribution made during the 2-year period ending on the change date shall, except as provided in regulations, be treated as part of a plan described in subparagraph (A).
Except as provided in regulations, any change in proportionate ownership which is attributable solely to fluctuations in the relative fair market values of different classes of stock shall not be taken into account.
The old loss corporation shall be treated as having substantial nonbusiness assets if at least ⅓ of the value of the total assets of such corporation consists of nonbusiness assets.
A regulated investment company to which part I of subchapter M applies, a real estate investment trust to which part II of subchapter M applies, or a REMIC to which part IV of subchapter M applies, shall not be treated as a new loss corporation having substantial nonbusiness assets.
For purposes of this paragraph, the term “nonbusiness assets” means assets held for investment.
For purposes of this paragraph, stock and securities in any subsidiary corporation shall be disregarded and the parent corporation shall be deemed to own its ratable share of the subsidiary’s assets. For purposes of the preceding sentence, a corporation shall be treated as a subsidiary if the parent owns 50 percent or more of the combined voting power of all classes of stock entitled to vote, and 50 percent or more of the total value of shares of all classes of stock.
In applying section 108(e)(8) to any case to which subparagraph (A) applies, there shall not be taken into account any indebtedness for interest described in subparagraph (B).
If, during the 2-year period immediately following an ownership change to which this paragraph applies, an ownership change of the new loss corporation occurs, this paragraph shall not apply and the section 382 limitation with respect to the 2nd ownership change for any post-change year ending after the change date of the 2nd ownership change shall be zero.
For purposes of this paragraph, the term “title 11 or similar case” has the meaning given such term by section 368(a)(3)(A).
A new loss corporation may elect, subject to such terms and conditions as the Secretary may prescribe, not to have the provisions of this paragraph apply.
If paragraph (5) does not apply to any reorganization described in subparagraph (G) of section 368(a)(1) or any exchange of debt for stock in a title 11 or similar case (as defined in section 368(a)(3)(A)), the value under subsection (e) shall reflect the increase (if any) in value of the old loss corporation resulting from any surrender or cancellation of creditors’ claims in the transaction.
The Secretary shall by regulation provide for the application of this section to the alternative tax net operating loss deduction under section 56(d).
Paragraph (1) shall not apply in the case of any subsequent ownership change unless such ownership change is described in such paragraph.
Paragraph (1) shall not apply in the case of any ownership change if, immediately after such ownership change, any person (other than a voluntary employees’ beneficiary association under section 501(c)(9)) owns stock of the new loss corporation possessing 50 percent or more of the total combined voting power of all classes of stock entitled to vote, or of the total value of the stock of such corporation.
[1] See Amendment of Subsection (
[1] )(3)(B)(iii) note below.
Pub. L. 115–97, title I, § 11051(b)(3)(F), (c), Dec. 22, 2017, 131 Stat. 2090, amended subsection (l)(3)(B)(iii) of this section, applicable to any divorce or separation instrument (as defined in former section 71(b)(2) of this title as in effect before Dec. 22, 2017) executed after Dec. 31, 2018, and to such instruments executed on or before Dec. 31, 2018, and modified after Dec. 31, 2018, if the modification expressly provides that the amendment made by section 11051 of Pub. L. 115–97 applies to such modification. After amendment, subsection (l)(3)(B)(iii) reads as follows:
(iii) stock is acquired by a person pursuant to any divorce or separation instrument (within the meaning of section 121(d)(3)(C)),
See 2017 Amendment note below.
The Emergency Economic Stabilization Act of 2008, referred to in subsec. (n)(1)(A), is div. A of Pub. L. 110–343, Oct. 3, 2008, 122 Stat. 3765, which is classified principally to chapter 52 (§ 5201 et seq.) of Title 12, Banks and Banking. For complete classification of this Act to the Code, see Short Title note set out under section 5201 of Title 12 and Tables.
2017—Subsec. (d)(3). Pub. L. 115–97, § 13301(b)(2), added par. (3).
Subsec. (k)(1). Pub. L. 115–97, § 13301(b)(3), inserted after first sentence “Such term shall include any corporation entitled to use a carryforward of disallowed interest described in section 381(c)(20).”
Subsec. (l)(3)(B)(iii). Pub. L. 115–97, § 11051(b)(3)(F), substituted “section 121(d)(3)(C)” for “section 71(b)(2)”.
2014—Subsec. (l)(5)(F) to (H). Pub. L. 113–295 redesignated subpars. (G) and (H) as (F) and (G), respectively, and struck out former subpar. (F) which related to a special rule for certain financial institutions for certain equity structure shifts and transactions occurring before May 10, 1989.
2009—Subsec. (n). Pub. L. 111–5 added subsec. (n).
2004—Subsec. (l)(4)(B)(ii). Pub. L. 108–357 substituted “or a REMIC to which part IV of subchapter M applies,” for “a REMIC to which part IV of subchapter M applies, or a FASIT to which part V of subchapter M applies,”.
1996—Subsec. (l)(4)(B)(ii). Pub. L. 104–188 substituted “a REMIC to which part IV of subchapter M applies, or a FASIT to which part V of subchapter M applies” for “or a REMIC to which part IV of subchapter M applies”.
1993—Subsec. (l)(5)(C). Pub. L. 103–66 amended heading and text of subpar. (C) generally. Prior to amendment, text read as follows:
“(i) In general.—In any case to which subparagraph (A) applies, 50 percent of the amount which, but for the application of section 108(e)(10)(B), would have been applied to reduce tax attributes under section 108(b) shall be so applied.
“(ii) Clarification with subparagraph (b).—In applying clause (i), there shall not be taken into account any indebtedness for interest described in subparagraph (B).”
1989—Subsec. (h)(3)(B)(i). Pub. L. 101–239, § 7205(a), amended cl. (i) generally. Prior to amendment, cl. (i) read as follows: “If the amount of the net unrealized built-in gain or net unrealized built-in loss (determined without regard to this subparagraph) of any old loss corporation is not greater than 25 percent of the amount determined for purposes of subparagraph (A)(i)(I), the net unrealized built-in gain or net unrealized built-in loss shall be zero.”
Subsec. (h)(6)(B). Pub. L. 101–239, § 7811(c)(5)(A)(i), inserted “(determined without regard to any carryover)” after “during the recognition period”.
Subsec. (h)(6)(C). Pub. L. 101–239, § 7811(c)(5)(A)(ii), substituted “which would be treated as recognized built-in gains or losses under this paragraph if such amounts were properly taken into account (or allowable as a deduction) during the recognition period” for “treated as recognized built-in gains or losses under this paragraph”.
Subsec. (l)(3)(B)(i)(III). Pub. L. 101–239, § 7841(d)(11), substituted “incident to divorce),” for “incident to divorce,”.
Subsec. (l)(3)(C). Pub. L. 101–239, § 7304(d)(1), redesignated subpar. (D) as (C) and struck out former subpar. (C) which related to special rule for employee stock ownership plans.
Subsec. (l)(3)(C)(ii). Pub. L. 101–239, § 7815(h), substituted “For purposes of subclause (III),” for “for purposes of subclause (III),” in concluding provisions.
Subsec. (l)(3)(D). Pub. L. 101–239, § 7304(d)(1), redesignated subpar. (D) as (C).
Subsec. (l)(5)(F). Pub. L. 101–73 substituted “on or after May 10, 1989” for “after December 31, 1989” in last sentence.
1988—Subsec. (e)(2). Pub. L. 100–647, § 1006(d)(1)(A), inserted “or other corporate contraction” after “redemption” in heading and in two places in text.
Subsec. (e)(3). Pub. L. 100–647, § 1006(d)(17)(A), added par. (3).
Subsec. (g)(1)(A). Pub. L. 100–647, § 1006(d)(21)(A), struck out “new” after “stock of the”.
Subsec. (g)(1)(B). Pub. L. 100–647, § 1006(d)(21)(B), struck out “old” after “stock of the”.
Subsec. (g)(4)(C). Pub. L. 100–647, § 1006(d)(2), inserted “rules similar to” after “provided in regulations,”.
Subsec. (h)(1)(C). Pub. L. 100–647, § 1006(d)(3)(A), substituted “Special rules for certain section 338 gains” for “Section 338 gain” in heading and amended text generally. Prior to amendment, text read as follows: “The section 382 limitation for any taxable year in which gain is recognized by reason of an election under section 338 shall be increased by the excess of—
“(i) the amount of such gain, over
“(ii) the portion of such gain taken into account in computing recognized built-in gains for such taxable year.”
Subsec. (h)(3)(A)(ii). Pub. L. 100–647, § 1006(d)(28)(A), inserted “to the extent provided in regulations,” after “an ownership change,”.
Pub. L. 100–647, § 1006(d)(1)(B), inserted “or other corporate contractions” after “redemptions” in heading and “or other corporate contraction” after “redemption” in two places in text.
Subsec. (h)(3)(B)(ii). Pub. L. 100–647, § 1006(d)(26), inserted “except as provided in regulations,” after “under clause (i),”.
Subsec. (h)(4). Pub. L. 100–647, § 1006(d)(20), substituted “allowed as a carryforward” for “treated as a net operating loss” in heading and inserted “(or to the extent the amount so disallowed is attributable to capital losses, under rules similar to the rules for the carrying forward of net capital losses)” after “net operating losses” in subpar. (A).
Subsec. (h)(5)(A). Pub. L. 100–647, § 1006(d)(3)(B), substituted “recognized built-in gains to the extent such gains increased the section 382 limitation for the year (or recognized built-in losses to the extent such losses are treated as pre-change losses)” for “recognized built-in gains and losses”.
Subsec. (h)(6). Pub. L. 100–647, § 1006(d)(22), substituted “Treatment of certain built-in items” for “Secretary may treat certain deductions as built-in losses” in heading and amended text generally. Prior to amendment, text read as follows: “The Secretary may by regulation treat amounts which accrue on or before the change date but which are allowable as a deduction after such date as recognized built-in losses.”
Subsec. (h)(9). Pub. L. 100–647, § 1006(d)(23), substituted “was acquired (or is subsequently transferred)” for “is transferred”.
Subsec. (i)(3). Pub. L. 100–647, § 1006(d)(4), inserted “the earlier of” after “not begin before” and “or the taxable year in which the transaction being tested occurs” after “1st post-change year”.
Subsec. (k)(1). Pub. L. 100–647, § 1006(d)(5)(A), inserted “or having a net operating loss for the taxable year in which the ownership change occurs” after “operating loss carryover”.
Subsec. (k)(2). Pub. L. 100–647, § 1006(d)(5)(B), amended par. (2) generally. Prior to amendment, par. (2) read as follows: “The term ‘old loss corporation’ means any corporation with respect to which there is an ownership change—
“(A) which (before the ownership change) was a loss corporation, or
“(B) with respect to which there is a pre-change loss described in subsection (d)(1)(B).”
Subsec. (l)(3)(A)(iv), (v). Pub. L. 100–647, § 1006(d)(6), added cls. (iv) and (v) and struck out former cl. (iv) which read as follows: “except to the extent provided in regulations, paragraph (4) of section 318(a) shall apply to an option if such application results in an ownership change.”
Subsec. (l)(3)(C)(ii). Pub. L. 100–647, § 5077(a), added subcl. (III) and concluding provisions.
Subsec. (l)(4)(B)(ii). Pub. L. 100–647, § 1006(t)(22)(A), substituted “REMIC” for “real estate mortgage pool”.
Subsec. (l)(5)(A)(ii). Pub. L. 100–647, § 1006(d)(25), substituted “stock of a controlling corporation” for “stock of controlling corporation”.
Pub. L. 100–647, § 1006(d)(7), substituted “after such ownership change and as a result of being shareholders or creditors immediately before such change” for “immediately after such ownership change”.
Subsec. (l)(5)(B). Pub. L. 100–647, § 1006(d)(27), substituted “the pre-change losses and excess credits (within the meaning of section 383(a)(2)) which may be carried to a post-change year shall be computed” for “the net operating loss deduction under section 172(a) for any post-change year shall be determined”.
Subsec. (l)(5)(C). Pub. L. 100–647, § 1006(d)(18), substituted “tax attributes” for “carryforwards” in heading and amended text generally. Prior to amendment, text read as follows: “In any case to which subparagraph (A) applies, the pre-change losses and excess credits (within the meaning of section 383(a)(2)) which may be carried to a post-change year shall be computed as if 50 percent of the amount which, but for the application of section 108(e)(10)(B), would have been includible in gross income for any taxable year had been so included.”
Subsec. (l)(5)(E). Pub. L. 100–647, § 1006(d)(19), substituted “taken into account” for “of creditors taken into account” in heading and amended introductory provisions generally. Prior to amendment, introductory provisions read as follows: “For purposes of subparagraph (A)(ii), stock transferred to a creditor in satisfaction of indebtedness shall be taken into account only if such indebtedness—”.
Subsec. (l)(5)(F). Pub. L. 100–647, § 4012(a)(3), substituted “1989” for “1988” in last sentence.
Subsec. (l)(5)(F)(i)(I). Pub. L. 100–647, § 1006(d)(8)(A), inserted “ ‘1504(a)(2)(B)’ for ‘1504(a)(2)’ and” after “by substituting”.
Subsec. (l)(5)(F)(ii)(III). Pub. L. 100–647, § 1006(d)(8)(B), substituted “the amount of deposits in the new loss corporation immediately after the change” for “deposits described in subclause (II)”.
Subsec. (l)(5)(F)(iii)(I). Pub. L. 100–647, § 4012(b)(1)(B), inserted “(as modified by section 368(a)(3)(D)(iv))” after “section 368(a)(3)(D)(ii)”.
Pub. L. 100–647, § 1006(d)(29), which directed amendment of subcl. (I) by substituting “section 368(a)(3)(D)(ii)” for “section 368(a)(D)(ii)”, could not be executed because “section 368(a)(3)(D)(ii)” appeared and “section 368(a)(D)(ii)” did not appear.
Subsec. (l)(6). Pub. L. 100–647, § 1006(d)(9), substituted “shall reflect the increase (if any) in value of the old loss corporation resulting from any surrender or cancellation of creditors’ claims in the transaction” for “shall be the value of the new loss corporation immediately after the ownership change”.
Subsec. (l)(8). Pub. L. 100–647, § 1006(d)(10), added par. (8).
Subsec. (m)(4). Pub. L. 100–647, § 1006(d)(1)(C), redesignated par. (5) as (4) and struck out former par. (4) which read as follows: “providing for the treatment of corporate contractions as redemptions for purposes of subsections (e)(2) and (h)(3)(A), and”.
Subsec. (m)(5). Pub. L. 100–647, § 1006(d)(24), added par. (5).
Pub. L. 100–647, § 1006(d)(1)(C), redesignated former par. (5) as (4).
1987—Subsec. (g)(4)(D). Pub. L. 100–203, § 10225(a), added subpar. (D).
Subsec. (h)(2)(B). Pub. L. 100–203, § 10225(b), inserted at end “Such term includes any amount allowable as depreciation, amortization, or depletion for any period within the recognition period except to the extent the new loss corporation establishes that the amount so allowable is not attributable to the excess described in clause (ii).”
1986—Pub. L. 99–514, § 621(a), in amending section generally, in subsec. (a), substituted provisions setting forth general rule that amount of taxable income of any new loss corporation for any post-change year which may be offset by pre-change losses shall not exceed section 382 limitation for such year for provisions relating to change in ownership of corporation and change in its business, description of persons owning corporation, attribution of ownership, and definition of “purchase”, in subsec. (b), substituted provisions relating to section 382 limitation for provisions relating to change in ownership as result of reorganization, in subsec. (c), substituted provisions relating to disallowance of carryforwards if continuity of business requirements are not met for provisions defining stock as all shares except nonvoting stock which is limited and preferred as to dividends, and added subsecs. (d) to (m).
Pub. L. 99–514, § 621(e)(1), repealed amendment by Pub. L. 94–455, § 806(e). See 1976 Amendment note below.
1984—Subsec. (b)(1). Pub. L. 98–369, in section as amended by Pub. L. 94–455, substituted “subparagraph (A), (B), (C), or (F) of section 368(a)(1) or subparagraph (D) or (G) of section 368(a)(1) (but only if the requirements of section 354(b)(1) are met)” for “section 368(a)(1)(A), (B), (C), (D) (but only if the requirements of section 354(b)(1) are met, or (F)”.
1981—Subsec. (b)(7). Pub. L. 97–34 designated existing provisions as subpar. (A) and added subpar. (B).
1980—Subsec. (b)(7). Pub. L. 96–589 added par. (7).
1976—Pub. L. 94–455, § 806(e), which amended section generally, substituting provisions relating to special limitations on net operating loss carryovers based on continuity of trade or business conducted, for provisions relating to special limitations on net operating loss carryovers based on continuity of ownership, was repealed by Pub. L. 99–514, § 621(e)(1). See Effective Date of 1986 and 1976 Amendment notes below.
1964—Subsec. (a)(3). Pub. L. 88–554 inserted reference to section 318(a)(3)(C) of this title.
Amendment by section 11051(b)(3)(F) of Pub. L. 115–97 applicable to any divorce or separation instrument (as defined in former section 71(b)(2) of this title as in effect before Dec. 22, 2017) executed after Dec. 31, 2018, and to such instruments executed on or before Dec. 31, 2018, and modified after Dec. 31, 2018, if the modification expressly provides that the amendment made by section 11051 of Pub. L. 115–97 applies to such modification, see section 11051(c) of Pub. L. 115–97, set out as a note under section 61 of this title.
Amendment by section 13301(b)(2), (3) of Pub. L. 115–97 applicable to taxable years beginning after Dec. 31, 2017, see section 13301(c) of Pub. L. 115–97, set out as a note under section 163 of this title.
Amendment by Pub. L. 113–295 effective Dec. 19, 2014, subject to a savings provision, see section 221(b) of Pub. L. 113–295, set out as a note under section 1 of this title.
Pub. L. 111–5, div. B, title I, § 1262(b), Feb. 17, 2009, 123 Stat. 344, provided that:
Amendment by Pub. L. 108–357 effective Jan. 1, 2005, with exception for any FASIT in existence on Oct. 22, 2004, to the extent that regular interests issued by the FASIT before such date continue to remain outstanding in accordance with the original terms of issuance, see section 835(c) of Pub. L. 108–357, set out as a note under section 56 of this title.
Amendment by Pub. L. 104–188 effective Sept. 1, 1997, see section 1621(d) of Pub. L. 104–188, set out as a note under section 26 of this title.
Amendment by Pub. L. 103–66 applicable to stock transferred after Dec. 31, 1994, in satisfaction of any indebtedness, except that such amendment inapplicable to stock transferred in satisfaction of any indebtedness if such transfer is in a title 11 or similar case filed on or before Dec. 31, 1993, see section 13226(a)(3) of Pub. L. 103–66, set out as a note under section 108 of this title.
Amendment by section 7205(a) of Pub. L. 101–239 applicable, except as otherwise provided, to ownership changes and acquisitions after Oct. 2, 1989, in taxable years ending after such date, see section 7205(c) of Pub. L. 101–239, set out as a note under section 56 of this title.
Pub. L. 101–239, title VII, § 7304(d)(2), Dec. 19, 1989, 103 Stat. 2354, provided that:
Amendment by sections 7811(c)(5)(A) and 7815(h) of Pub. L. 101–239 effective, except as otherwise provided, as if included in the provision of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100–647, to which such amendment relates, see section 7817 of Pub. L. 101–239, set out as a note under section 1 of this title.
Pub. L. 101–73, title XIV, § 1401(c)(2), Aug. 9, 1989, 103 Stat. 550, provided that:
Pub. L. 100–647, title I, § 1006(d)(1)(D), Nov. 10, 1988, 102 Stat. 3395, provided that:
Pub. L. 100–647, title I, § 1006(d)(17)(B), Nov. 10, 1988, 102 Stat. 3398, provided that:
Pub. L. 100–647, title I, § 1006(d)(28)(B), Nov. 10, 1988, 102 Stat. 3400, provided that:
Amendment by section 1006(d)(2)–(10), (18)–(27), (29), (t)(22)(A) of Pub. L. 100–647 effective, except as otherwise provided, as if included in the provision of the Tax Reform Act of 1986, Pub. L. 99–514, to which such amendment relates, see section 1019(a) of Pub. L. 100–647, set out as a note under section 1 of this title.
Pub. L. 100–647, title IV, § 4012(b)(1)(C)(ii), Nov. 10, 1988, 102 Stat. 3657, provided that:
Pub. L. 100–647, title V, § 5077(b), Nov. 10, 1988, 102 Stat. 3683, provided that:
Pub. L. 100–203, title X, § 10225(c), Dec. 22, 1987, 101 Stat. 1330–413, provided that:
Pub. L. 99–514, title VI, § 621(f), Oct. 22, 1986, 100 Stat. 2266, as amended by Pub. L. 100–647, title I, § 1006(d)(11)–(16), title VI, § 6277(a), (b), Nov. 10, 1988, 102 Stat. 3397, 3398, 3753, 3754, provided that:
[Pub. L. 100–647, title VI, § 6277(c), Nov. 10, 1988, 102 Stat. 3754, provided that:
Pub. L. 98–369, div. A, title I, § 62(b)(2), July 18, 1984, 98 Stat. 583, provided that:
Amendment by Pub. L. 97–34 applicable to any transfer made on or after Jan. 1, 1981, see section 246(a) of Pub. L. 97–34, set out as a note under section 368 of this title.
Pub. L. 96–589, § 2(d), Dec. 24, 1980, 94 Stat. 3396, provided that the amendment made by section 2(b) of Pub. L. 96–589 is to subsec. (b) as in effect before its amendment by section 806 of the Tax Reform Act of 1976, Pub. L. 94–455.
Amendment by Pub. L. 96–589 applicable to transactions which occur after Dec. 31, 1980, other than transactions which occur in a proceeding in a bankruptcy case or similar judicial proceeding or in a proceeding under Title 11 commencing on or before Dec. 31, 1980, with an exception permitting the debtor to make the amendment applicable to transactions occurring after Sept. 30, 1979, in a specified manner, see section 7(a)(1), (f) of Pub. L. 96–589, set out as a note under section 108 of this title.
Pub. L. 94–455, title VIII, § 806(g)(2), (3), Oct. 4, 1976, 90 Stat. 1605, 1606, as amended by Pub. L. 95–600, title III, § 368(a), Nov. 6, 1978, 92 Stat. 2857; Pub. L. 95–615, § 8, Nov. 8, 1978, 92 Stat. 3098; Pub. L. 96–167, § 9(e), Dec. 29, 1979, 93 Stat. 1279; Pub. L. 97–119, title I, § 111, Dec. 29, 1981, 95 Stat. 1640; Pub. L. 98–369, div. A, title I, § 62(a), July 18, 1984, 98 Stat. 583, which provided an effective date for the amendments made by section 806(e), (f) of Pub. L. 94–455 for purposes of applying sections 382(a) and 383 (as it relates to section 382(a)) of this title, was repealed by Pub. L. 99–514, title VI, § 621(e)(2), (f)(2), Oct. 22, 1986, 100 Stat. 2266, eff. Jan. 1, 1986.
Amendment by Pub. L. 88–554 effective Aug. 31, 1964, except that for purposes of sections 302 and 304 of this title, such amendment shall not apply to distributions in payment for stock acquisitions or redemptions, if such acquisitions or redemptions occurred before Aug. 31, 1964, see section 4(c) of Pub. L. 88–554, set out as a note under section 318 of this title.
Pub. L. 95–600, title III, § 368, Nov. 6, 1978, 92 Stat. 2857, provided for delaying the effective date established by section 806(g)(2), (3) of Pub. L. 94–455, formerly set out above, by substituting “1980” for “1978”, with certain elections.
Pub. L. 111–5, div. B, title I, § 1261, Feb. 17, 2009, 123 Stat. 342, provided that:
Pub. L. 99–514, title VI, § 621(d), Oct. 22, 1986, 100 Stat. 2266, directed Secretary of the Treasury or his delegate to, not later than Jan. 1, 1989, conduct a study and report to Committee on Ways and Means of House of Representatives and Committee on Finance of Senate with respect to treatment of depreciation, amortization, depletion, and other built-in deductions for purposes of sections 382 and 383 of this title, and, not later than Jan. 1, 1988, conduct a study and report to committees referred to above with respect to treatment of informal bankruptcy workouts for purposes of sections 108 and 382 of this title, prior to repeal by Pub. L. 101–508, title XI, § 11832(3), Nov. 5, 1990, 104 Stat. 1388–559.
Written determinations for this section
These documents, sometimes referred to as "Private Letter Rulings", are taken from the IRS Written Determinations page; the IRS also publishes a fuller explanation of what they are and what they mean. The collection is updated (at our end) daily. It appears that the IRS updates their listing every Friday.
Note that the IRS often titles documents in a very plain-vanilla, duplicative way. Do not assume that identically-titled documents are the same, or that a later document supersedes another with the same title. That is unlikely to be the case.
Release dates appear exactly as we get them from the IRS. Some are clearly wrong, but we have made no attempt to correct them, as we have no way guess correctly in all cases, and do not wish to add to the confusion.
We truncate results at 20000 items. After that, you're on your own.
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2017-12-15
- Other : 2017-08-25
- Closing of the Books : 2017-08-25
- General Rule : 2016-11-25
- Title 11 or Similar Case : 2016-11-25
- Net Unrealized Built-in Gain : 2016-07-15
- Built-in Gains and Losses and Section 338 Gains : 2016-07-15
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2015-12-04
- Other : 2015-11-06
- Closing of the Books : 2015-11-06
- Other : 2015-05-08
- Election Out : 2015-05-08
- Segregation Rules : 2014-12-19
- Other : 2014-10-24
- Operating Rules : 2014-10-24
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2014-10-24
- Controlled Groups : 2014-10-24
- Title 11 or Similar Case : 2014-08-29
- Value of Old Loss Corporation : 2014-08-29
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2014-08-08
- Other : 2014-05-23
- Controlled Groups : 2014-05-23
- Other : 2014-05-23
- Controlled Groups : 2014-05-23
- Other : 2014-05-23
- Controlled Groups : 2014-05-23
- Other : 2014-05-02
- Closing of the Books : 2014-05-02
- Other : 2014-03-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2014-03-21
- Other : 2014-02-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2014-02-21
- Definitions and Special Rules : 2014-01-17
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2014-01-17
- 5-Percent Shareholder : 2014-01-17
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-12-13
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-11-08
- Other : 2013-08-30
- Operating Rules : 2013-08-30
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-08-30
- Controlled Groups : 2013-08-30
- Affiliated Group v. Not an Affiliated Group : 2013-07-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-07-12
- Title 11 or Similar Case : 2013-07-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-06-28
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-05-31
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-04-05
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-03-01
- Carryback and Carryover : 2013-03-01
- Taxable Income Defined : 2013-03-01
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-02-22
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-02-22
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-02-08
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2013-02-01
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2012-12-21
- Other : 2012-08-10
- Controlled Groups : 2012-08-10
- Other : 2012-08-10
- Controlled Groups : 2012-08-10
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2012-07-20
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2012-07-13
- Year Liquidation Occurs : 2012-07-13
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2012-04-13
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2012-02-24
- Other : 2011-12-23
- Controlled Groups : 2011-12-23
- Other : 2011-11-10
- Controlled Groups : 2011-11-10
- Other : 2011-10-28
- Election Out : 2011-10-28
- Other : 2011-09-23
- Extension of Time for Making Certain Elections : 2011-09-23
- Election Out : 2011-09-23
- Operating Rules : 2011-09-23
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-09-23
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-08-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-07-01
- Operating Rules : 2011-06-17
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-06-17
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-04-08
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-03-11
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-02-11
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-02-04
- Tax Imposed On Certain Built-In Gains for Corporations Electing S Status After 12 31 86 : 2011-02-04
- Other : 2011-02-04
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2011-02-04
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-12-23
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-12-23
- Operating Rules : 2010-10-29
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-10-29
- Fluctuation in Value : 2010-10-29
- Segregation Rules : 2010-10-01
- Operating Rules : 2010-10-01
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-10-01
- Fluctuation in Value : 2010-10-01
- Ownership Change : 2010-10-01
- Fluctuation in Value : 2010-08-13
- Other : 2010-07-30
- Closing of the Books : 2010-07-30
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-07-16
- Limitation on Capital Losses and Excess Credits : 2010-07-16
- Fluctuation in Value : 2010-07-09
- Ownership Change : 2010-07-09
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-06-18
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-04-30
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-04-30
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-04-30
- Other : 2010-04-23
- Operating Rules : 2010-04-23
- Controlled Groups : 2010-04-23
- Other : 2010-04-23
- Operating Rules : 2010-04-23
- Controlled Groups : 2010-04-23
- Fluctuation in Value : 2010-04-16
- Title 11 or Similar Case : 2010-03-12
- Fluctuation in Value : 2010-03-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-02-05
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-01-22
- Tax Imposed On Certain Built-In Gains for Corporations Electing S Status After 12 31 86 : 2010-01-22
- Other : 2010-01-22
- Election Out : 2010-01-22
- Operating Rules : 2010-01-08
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2010-01-08
- Fluctuation in Value : 2010-01-08
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-12-25
- Fluctuation in Value : 2009-12-25
- Other : 2009-12-04
- Controlled Groups : 2009-12-04
- Other : 2009-12-04
- Controlled Groups : 2009-12-04
- Other : 2009-12-04
- Controlled Groups : 2009-12-04
- Other : 2009-12-04
- Controlled Groups : 2009-12-04
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-09-18
- Definitions : 2009-08-28
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-08-28
- Segregation Rules : 2009-08-21
- Fluctuation in Value : 2009-08-21
- Constructive Ownership of Stock : 2009-08-21
- Insolvency Transactions : 2009-08-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-06-26
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-04-10
- Split-Off : 2009-02-27
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-02-27
- Other : 2009-01-23
- Controlled Groups : 2009-01-23
- Other : 2009-01-23
- Controlled Groups : 2009-01-23
- Other : 2009-01-23
- Controlled Groups : 2009-01-23
- Other : 2009-01-23
- Controlled Groups : 2009-01-23
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-01-09
- 5-Percent Shareholder : 2009-01-09
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-01-02
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2009-01-02
- Fluctuation in Value : 2009-01-02
- Split-Off : 2008-12-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-12-12
- Other : 2008-11-14
- Controlled Groups : 2008-11-14
- Split-Off : 2008-10-10
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-10-10
- Split-Off : 2008-09-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-09-12
- Other : 2008-09-12
- Closing of the Books : 2008-09-12
- Other : 2008-09-12
- Closing of the Books : 2008-09-12
- Other : 2008-09-12
- Closing of the Books : 2008-09-12
- Other : 2008-09-12
- Closing of the Books : 2008-09-12
- Other : 2008-09-12
- Closing of the Books : 2008-09-12
- Other : 2008-08-08
- Closing of the Books : 2008-08-08
- Controlled Groups : 2008-08-08
- Other : 2008-08-01
- Controlled Groups : 2008-08-01
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-05-30
- 5-Percent Shareholder : 2008-05-30
- Title 11 or Similar Case : 2008-05-02
- Extension of Time for Making Certain Elections : 2008-04-18
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-04-18
- Controlled Groups : 2008-04-18
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-04-04
- Ownership Change : 2008-03-07
- Constructive Ownership of Stock : 2008-03-07
- Hospitals and Health Clinics See Also 0501.06-03 : 2008-03-07
- Other : 2008-02-15
- Controlled Groups : 2008-02-15
- Other : 2008-02-15
- Controlled Groups : 2008-02-15
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2008-02-08
- When Group Remains in Existence : 2007-12-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2007-12-21
- Ownership Change of a Loss Group : 2007-12-21
- Transfer by Corporation in Title 11 Case Type G : 2007-12-21
- Reduction of Tax Attributes : 2007-12-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2007-12-21
- Qualified Payment : 2007-12-21
- Ownership Change : 2007-11-30
- 3-year Period : 2007-11-30
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2007-11-23
- 5-Percent Shareholder : 2007-11-23
- Title 11 or Similar Case : 2007-08-03
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2007-07-27
- Other : 2007-07-06
- Controlled Groups : 2007-07-06
- Ownership Change : 2007-05-18
- 3-year Period : 2007-05-18
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2007-03-30
- Other : 2006-11-17
- Controlled Groups : 2006-11-17
- Other : 2006-09-08
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2006-09-08
- Other : 2006-09-08
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2006-09-08
- Other : 2006-06-02
- Controlled Groups : 2006-06-02
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2006-06-02
- Ownership Change : 2006-06-02
- Owner Shift : 2006-06-02
- Fluctuation in Value : 2006-06-02
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2006-05-05
- Other : 2006-03-31
- Controlled Groups : 2006-03-31
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2006-02-03
- Other : 2006-01-27
- Controlled Groups : 2006-01-27
- Other : 2006-01-20
- Controlled Groups : 2006-01-20
- Other : 2006-01-20
- Controlled Groups : 2006-01-20
- Other : 2006-01-20
- Controlled Groups : 2006-01-20
- Other : 2006-01-20
- Controlled Groups : 2006-01-20
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-12-09
- Excess Losses : 2005-12-09
- Definition Life Insurance Company : 2005-12-09
- Applicability of Other Provisions of Law : 2005-12-09
- Other : 2005-10-28
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-28
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Other : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-10-21
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-05-20
- Other : 2005-05-06
- Controlled Groups : 2005-05-06
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-04-01
- Value of Old Loss Corporation : 2005-04-01
- Extension of Time for Making Certain Elections : 2005-04-01
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-04-01
- Extension of Time for Making Certain Elections : 2005-04-01
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2005-04-01
- Fluctuation in Value : 2005-03-18
- Title 11 or Similar Case : 2005-03-04
- Ownership Change : 2005-03-04
- Treating Interests As Stock : 2005-03-04
- Title 11 or Similar Case : 2004-11-05
- Ownership Change : 2004-11-05
- Treating Interests As Stock : 2004-11-05
- Other : 2004-11-05
- Controlled Groups : 2004-11-05
- Other : 2004-11-05
- Controlled Groups : 2004-11-05
- Other : 2004-11-05
- Controlled Groups : 2004-11-05
- Title 11 or Similar Case : 2004-10-15
- Taxation of Designated Settlement Funds : 2004-10-15
- Fluctuation in Value : 2004-03-12
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2004-02-06
- Extension of Time for Making Certain Elections : 2003-11-28
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2003-11-28
- Extension of Time for Making Certain Elections : 2003-08-15
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2003-08-15
- Other : 2003-07-18
- Closing of the Books : 2003-07-18
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2003-06-27
- Earnings and Profits : 2003-04-25
- Ownership Change : 2003-04-25
- Dividend in Property : 2003-04-25
- Recapitalization Type E : 2003-04-25
- Extension of Time for Making Certain Elections : 2003-02-07
- Closing of the Books : 2003-02-07
- Closing of the Books : 2003-01-03
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2002-11-08
- Title 11 or Similar Case : 2002-10-25
- Special Rules For Designated Settlement Funds : 2002-10-25
- General Rules for Discharges of Indebtedness : 2002-10-25
- 10-Year Carryover : 2002-10-25
- Exclusion From Gross Income : 2002-10-18
- Title 11 or Similar Case : 2002-10-18
- Designated Settlement Fund : 2002-10-18
- Definitions : 2002-09-20
- General Rule : 2002-09-20
- Allocation of Income and Deductions Among Taxpayers : 2002-09-20
- Liquidations After Qualified Stock Purchases : 2002-09-20
- General Rule : 2002-06-21
- Earnings and Profits : 2002-06-21
- Dividend v. Not a Dividend : 2002-06-21
- Extension of Time for Making Certain Elections : 2002-05-17
- Closing of the Books : 2002-05-17
- Net Unrealized Built-in Gain : 2002-04-26
- Equity Structure Shift : 2002-02-15
- General Rule : 2002-02-15
- Extension of Time for Making Certain Elections : 2002-01-11
- Controlled Groups : 2002-01-11
- Extension of Time for Making Certain Elections : 2002-01-11
- Controlled Groups : 2002-01-11
- Interest : 2001-10-26
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2001-10-26
- Trade or Business Deductible v. Not Deductible : 2001-10-26
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2001-10-05
- Extension of Time for Making Certain Elections : 2001-07-27
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2001-07-27
- Extension of Time for Making Certain Elections : 2001-06-22
- Closing of the Books : 2001-06-22
- Extension of Time for Making Certain Elections : 2001-03-23
- Closing of the Books : 2001-03-23
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2000-07-14
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 2000-07-07
- General Rule : 2000-06-16
- Constructive Ownership of Stock : 2000-03-10
- Net Unrealized Built-in Loss : 2000-03-10
- Preferred Stock : 2000-03-10
- Reduction of Carryovers : 2000-02-11
- Reduction for Interest Payment : 2000-02-11
- Consolidated Net Operating Loss Deduction : 1999-12-10
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 1999-12-10
- Consolidated Returns : 1999-12-10
- Built-in Gains and Losses and Section 338 Gains : 1999-10-22
- Consolidated Net Operating Loss Deduction : 1999-07-23
- When Group Remains in Existence : 1999-07-23
- Limitation on Net Operating Loss Carry-forwards and Built-in Losses Following Ownership Changes : 1999-07-23
- Constructive Ownership of Stock : 1999-05-07
- Built-in Gains and Losses and Section 338 Gains : 1999-04-09
- Property Differing Materially : 1999-03-12
- Treating Interests As Stock : 1999-03-12
- Treating Stock As Not Stock : 1999-03-12
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