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Further Discussions on I.R.C. Section 382

Should section 382’s limitation be apportioned for state income tax purposes?


Of the states that have conformed to I.R.C. §382, some have required that the limitation imposed on taxpayer losses following an ownership change be apportioned in determining the amount of state net operating losses that can be used in a given tax year. In this article Brian Sullivan and Meredith Morgan, of Deloitte Tax LLP’s Multistate Tax Transaction Advisory Services, discuss how the resolution of apportionment issues with respect to net operating losses can depend on the express rule-making authority granted to state taxing agencies related to the state’s conformity to I.R.C. §382.

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