• Partial Offer for Chong Hing Bank Limited: Takeover Code Lessons
  • November 7, 2013
  • Law Firm: Sullivan Cromwell LLP - New York Office
  • 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 October 22, 2013, the Internal Revenue Service adopted Final Regulations intended to lessen the compliance burden on a corporation determining whether it has experienced an ownership change for these purposes. The Final Regulations are based upon and take into account comments received in respect of the Proposed Regulations issued on November 22, 2011. The Final Regulations are generally effective from October 22, 20 13 but can in some cases be applied to transactions occurring prior to that date.