Subchapter C -- Loss Carryovers Following Reorganizations and Changes in Ownership

• Published in: The Tax Adviser Vol. 18; no. 4; p. 226
• Main Author: Worthy, K Martin
• Format: Trade Publication Article
• Language: English
• Published: New York American Institute of Certified Public Accountants 01.04.1987
• Subjects: Capital losses; Carryover; Changes; Corporate reorganization; Corporate tax planning; Foreign tax credits; Internal Revenue Code; Limits; Losses; Ownership; Ownership changes; Supreme Court decisions; Tax credits; Tax Reform Act 1986-US; Tests

Over the last decade, loss carryovers following reorganizations and certain stock purchases have been subject to limitations of uncertain application. New Internal Revenue Code (IRC) Section 382 shifts the method of limitation away from the loss carryover itself to the subsequent earnings of the con...