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potatoclump

10/31/18 3:36 PM

#30182 RE: Jerm17 #30181

they can't use the tax credits:

Section 621 (page 170) - https://www.ucop.edu/research-policy-analysis-coordination/_files/Public%20Law%2099-514.pdf

'(c) CARRYFORWARDS DISALLOWED IF CONTINUITY OF BUSINESS REQUIREMENTS MET.-"(1) IN GENERAL.-Except as provided in paragraph (2), if the new loss corporation does not continue the business enterprise of the old loss corporation at all times during the 2-year period beginning on the change date, the section 382 limitation for any post-change year shall be zero.'

Section 382, which is being referred to above, is where it is allowed for a business to carry forward pre-change (acquisition) NOLs into the post-change business enterprise.