Publisher's Synopsis
Excerpt from Description of Proposal Relating to Special Limitations on the Carryover of Net Operating Losses and Other Tax Attributes of Corporations: Scheduled for a Hearing Before the Subcommittee on Select Revenue Measures of the Committee on Ways and Means on September 22, 1983
In situations where control of the loss corporation changes through sales or exchanges (or redemptions) of its stock but the loss company continues in existence without any infusion of capi tal, a purchase rule would apply to limit the amount of carried over tax benefits to an amount that approximates the amount that could have been used had no change of ownership occurred and had the loss company invested the assets it held at the time of the change of ownership in taxable assets. N ols incurred by a corpora tion would be deductible as carryovers after a change in ownership only to the extent of a specified rate of return, re?ecting an after tax yield, on the price paid for the corporation's stock.
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