Michael J. Rosenthal

Proposed Regulations Seek to Ease Compliance with the Loss Trafficking Rules: Treasury Issues Notice of Proposed Rulemaking Limiting the Application of the Section 382 Segregation Rules in Certain Circumstances
Ronald E. Creamer,Michael J. Rosenthal,S. Eric Wang, December 1, 2011
Under Section 382 of the Internal Revenue Code, a corporation’s use of net operating losses is limited if there is an “ownership change.” On November 22, 2011, the Department of Treasury issued a Notice of Proposed Rulemaking (the “Notice”) containing proposed...