Accounting & the 3 StatementsHard

What is the Section 382 limitation, and why does it matter when valuing a target's NOLs in M&A or an LBO?

Model answer

IRC Section 382 limits how much of an acquired company's pre-change NOLs (and certain built-in losses) the buyer can use each year AFTER an 'ownership change' (broadly, a >50-percentage-point shift…

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