IRS Proposed Regulations Significantly Reduce the Annual Limitation Imposed on NOLs Following an Ownership Change
On September 9, 2019, the Treasury Department and the IRS issued proposed regulations (the “Proposed Regulations”) under Section 382 of the Internal Revenue Code of 1986 (the “Code”). If finalized, the Proposed Regulations will impose stricter limitations on the ability of a corporation with net operating losses (“NOLs”) to utilize such NOLs following an ownership change.
The Proposed Regulations are expected to adversely affect the valuation of the tax attributes of certain corporations.