"If the target's basis in its assets exceeds the enterprise value of the target at the time of a qualifying change in ownership (a "built-in loss"), the excess is treated as a NOL as described above. Likewise, if a target's basis in its asset is less than its enterprise value (a "built-in gain"), the Section 382 limitation for any year following the ownership change is increased by the amount of any such gain realized in that year. So, a buyer planning to divest unwanted assets of the target following the transaction may find the Section 382 limitation less onerous than it at first appears."
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