Changes of Ownership
The IRS limits the ability of a company to use accumulated net operating losses (NOLs) after completion of a merger or even a large financing.
Determining the usability of NOLs under IRC 382 requires a detailed analysis of changes in a company’s ownership over a three year period, possibly including the value of the company at various dates. Teknos can perform the necessary calculations required by IRC 382, including tracking first-tier and higher-tier entities to follow 5% shareholders (constructive ownership and attribution), carving out “small issuance” and “cash issuance” exceptions, and other details, plus perform any necessary valuation work.
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