If I understand correctly, if a 100% change in ownership occurs at 7/1/17 for a calendar year C corp that has taxable income of 15K for the whole year, and the NOL carryover from 2016 is 30K, then 7,500 of the taxable income can be offset by the NOL carryover from 2016 (prorated on a daily basis for half of the year), leaving 22,500 of NOL that must be limited each year based on S382. So if the 2017 limitation is 1K, then the total NOL that is taken on the 2017 tax return is 8,500. Does this sound correct? Thanks.
13-Jul-2018 4:22pm
