94-455, 806(f)(2), as related to section 382(a) of this title, substituted “with respectthe IRC. IRC sections 382, 383 and 384 are contained in Subchapter C. 382 limitation - determining value of the old loss corporation.
How current is the last Section 382 Study? Stated another way, has your company updated its study on a regular basis? If so, then the current Section 382 study should simply pick up where the last Section 382 Study left off. If not, then the scope of your current Section 382 study will need to be determined up front. You will need to identify 5-percent shareholders and certain transactions that should have been evaluated in the previous study to determine whether Section 382 was triggered. The corporation with the preceding items isTo any unused business credit of the corporation which can otherwise be carried forwardIRC 382 for Tax Loss Carryforwards The IRC 382 lays down the guidelines for the amount of taxable income that can be offset by historical losses, known as a.Under section 39, to any unused credit of the corporation which could otherwise beCarried forward under section 30(g)(2), to any excess foreign taxes of the corporationWhich could otherwise be carried forward under section 904(c), and to any net capitalLoss of the corporation which can otherwise be carried forward under section 1212”For “with respect to any unused investment credit of the corporation which can otherwiseBe carried forward under section 46(b), to any unused work incentive program creditOf the corporation which can otherwise be carried forward under section 50A(b), toAny unused new employee credit of the corporation which could otherwise be carriedForward under section 53(b), to any unused credit of the corporation which could otherwiseBe carried forward under section 44E(e)(2), to any unused credit of the corporationWhich could otherwise be carried forward under section 44F(g)(2), to any unused creditOf the corporation which could otherwise be carried forward under section 44G(b)(2),To any excess foreign taxes of the corporation which can otherwise be carried forwardUnder section 904(c), and to any net capital loss of the corporation which can otherwisePub. 98-369, 474(r)(12)(B)(i), in section 383, as amended by Pub. 94-455, 806(f)(2), as related to section 382(a) of this title, substituted “with respectTo any unused business credit of the corporation under section 39, to any unused creditOf the corporation under section 30(g)(2), to any excess foreign taxes of the corporationUnder section 904(c), and to any net capital loss of the corporation under section1212” for “with respect to any unused investment credit of the corporation under section46(b), to any unused work incentive program credit of the corporation under section50A(b), to any unused new employee credit of the corporation under section 53(b),To any unused credit of the corporation under section 44E(e)(2), to any unused creditOf the corporation under section 44F(g)(2), to any unused credit of the corporationUnder section 44G(b)(2), to any excess foreign taxes of the corporation under section904(c), and to any net capital loss of the corporation under section 1212”. Return Limitation Year (SRLY) limitation set forth in Treasury Regulation.Pub.
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