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Re: marayatano post# 8861

Wednesday, 03/21/2012 12:00:04 AM

Wednesday, March 21, 2012 12:00:04 AM

Post# of 111126
I failed to see how the quote you just provided:

If, during the 2-year period immediately following an ownership change to which this paragraph applies, an ownership change of the new loss corporation occurs, this paragraph shall not apply and the section 382 limitation with respect to the 2nd ownership change for any post-change year ending after the change date of the 2nd ownership change shall be zero.

leads to your earlier statement:

"IRS allows 1 change of ownership every 2 years and still preserve tax attributes."

Do you mind connecting the dots?