Internal R Evenue S Ervice

NOL Carryforward Use Limitation After the Ownership …

(NOL) carryforward income tax benefits. Internal Revenue Code Section 382 limits the . taxpayer corporation’s use of the NOL tax benefit when there is a change of ownership. Some change in ownership transactions (e.g., mergers and acquisitions) are obvious. Other change in ownership transaction (e.g., private equity investments, debt private

  Internal, After, Ownership, Limitations, Carryforward, Nol carryforward use limitation after the ownership

UNITED STATES COURT OF APPEALS FOR THE NINTH CIRCUIT

complaint, Plaintiffs asserted that, because the IRS’s claim for penalties was a “claim of a kind specified in section 726(a)(4)” of Title 11 of the U.S. Code, the “lien that secures” that penalties claim was subject to avoidance by the trustee under § 724(a).