WebIt is a tax code that allows for the depreciation of certain types of intangible assets. IRC section 382 (a) is the most common form, and it applies to a wide variety of intangible assets, including patents, copyrights, and trademarks. IRC section 382 (b) applies to patents only. It allows companies to depreciate their patent costs over 15 ... Web1 Nov 1992 · The option attribution rules in Sec. 382 (1) (3) and Temp. Regs. Sec. 1.382-2T (h) (4) continue to frustrate taxpayers by causing unexpected ownership changes that impair the use of net operating loss (NOL) and other tax attribute carryovers. An understanding of these complex rules, including the pitfalls and planning opportUnities, is needed ...
Credits and NOLs Under Section 382 & More Section 382 …
Web14 Apr 2024 · Tax Advisory: U.S. Federal. The Inflation Reduction Act (IRA) extended and expanded the Section 30D Clean Vehicle (CV) Credit, previously known as the Electric Vehicle (EV) Credit. The credit now covers “clean vehicles,” which include plug-in hybrids, hydrogen fuel cell cars and EVs. On April 17, 2024, the IRS will publish proposed ... Web§ 9.16 Why You Should Be Using a Board of Advisors and How to Get the Most Benefit From It ..... 9-72 § 9.17 Form of Stock Incentive Plan ..... 9-74 § 9.18 Form of Master Services Agreement with Statement of Work ..... 9-90 § 9.19 Form of Non-Disclosure Agreement with Amendment No. 1 ..... linda wells attorney peachtree city
SECTION 382 RIGHTS AGREEMENT between TENET …
Web24 Mar 2024 · However, as noted earlier, a debt pushdown may limit the use of a target’s pre- acquisition losses under the section 382 regime (see ‘Tax losses and other attributes’ … Web4 Nov 2024 · On December 15, 2024, LossCo’s shareholders sold all of their stock to an unrelated third party, causing LossCo to undergo a section 382 ownership change. On … WebCongress enacted Internal Revenue Code Secs. 382 and 383 to prevent companies from acquiring targets for the express purpose of using their net operating losses (NOLs) and tax credits. Section 382 limits the use of a target’s pre-acquisition NOL carryforward to an amount equal to the product of the fair market value (FMV) of the target’s ... linda wells cpa