Net Operating Loss Analysis and Planning

 An "ownership change" under section 382 of the Internal Revenue Code  will cause the impairment or even total loss of a corporation's net operating loss carryovers and other valuable tax attributes.   It is essential to understand how detailed Treasury regulations cause 5% shareholders to be identified and tracked to avoid an ownership change and, if an ownership change is unavoidable, how to maximize the benefit of existing tax carryovers.

John Brogan and his team have helped numerous publicly held and private companies in understanding their section 382 posture and the financing alternatives that will preserve the value of tax attributes.