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#7
09-13-2004, 08:41 PM
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 Re: Corporation with large NOL - quote - > > > > Any ideas for a C-corporation with a huge NOL? It is unlike
Since when did bankruptcy enter the equation? Simply having> > > > they will be getting any significant revenue. It's a > > > > start-up with a lot of expenses, but no sales. > > > If you want to get creative, maybe somebody would be willing > > > to buy all the stock of that corporation so they can turn it > > > into a profitable company and use up the NOL. > > And ignore the §382 limitations on change of ownership? > The company could file for bankruptcy in which case §382 > doesn't apply. a large NOL doesn't mean the company is insolvent. For all we know the company was funded solely through stock and equity. If the net worth is positive and there is little to no debt, what would filing for bankruptcy accomplish? -- David M. Woods, EA, ChFC, CLU Woods Financial Services Norwood, MA 02062 www.woods-financial.com << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#6
09-13-2004, 08:41 PM
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| Re: Corporation with large NOL - quote - > > > > Any ideas for a C-corporation with a huge NOL?
Robert J. Romano, CPA wrote:> > > > It is unlike they will be getting any significant > > > > revenue. It's a start-up with a lot of expenses, > > > > but no sales. > > > If you want to get creative, maybe somebody would be > > > willing to buy all the stock of that corporation so > > > they can turn it into a profitable company and use up > > > the NOL. > > And ignore the §382 limitations on change of > > ownership? - quote - > The company could file for bankruptcy in which case
For the section 382 limitation to not apply in bankruptcy,> §382 doesn't apply. control of the company must still end up with the pre- bankruptcy shareholders and the pre-bankruptcy creditors. It works about the same way as the normal 382 limits, but you get to count the creditors who end up with part of the company in tbe bankruptcy as part of the pre-bankruptcy control group. It would be hard to use these rules as a way to sell the company off for value other than in pretty limited circumstances. Brian Bivona, CPA << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#5
09-11-2004, 02:26 AM
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| Re: Corporation with large NOL - quote - > > > Any ideas for a C-corporation with a huge NOL? It is unlike
The company could file for bankruptcy in which case §382> > > they will be getting any significant revenue. It's a > > > start-up with a lot of expenses, but no sales. > > If you want to get creative, maybe somebody would be willing > > to buy all the stock of that corporation so they can turn it > > into a profitable company and use up the NOL. > And ignore the §382 limitations on change of ownership? doesn't apply. -- Robert J. Romano, CPA 99 Massachusetts Avenue-Suite 4 Arlington, Massachusetts 02474-8600 www.romanocpa.com << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#4
09-09-2004, 03:30 PM
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| Re: Corporation with large NOL "Robert J. Romano, CPA" <bob[at]romanocpa.com> wrote: - quote - > > Any ideas for a C-corporation with a huge NOL? It is unlike
And ignore the §382 limitations on change of ownership?> > they will be getting any significant revenue. It's a > > start-up with a lot of expenses, but no sales. > If you want to get creative, maybe somebody would be willing > to buy all the stock of that corporation so they can turn it > into a profitable company and use up the NOL. -- David M. Woods, EA, ChFC, CLU Woods Financial Services Norwood, MA 02062 www.woods-financial.com << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#3
09-08-2004, 06:46 PM
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| Re: Corporation with large NOL - quote - > Any ideas for a C-corporation with a huge NOL? It is unlike
If you want to get creative, maybe somebody would be willing> they will be getting any significant revenue. It's a > start-up with a lot of expenses, but no sales. to buy all the stock of that corporation so they can turn it into a profitable company and use up the NOL. -- Robert J. Romano, CPA 99 Massachusetts Avenue-Suite 4 Arlington, Massachusetts 02474-8600 www.romanocpa.com << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#2
09-08-2004, 04:51 PM
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| Re: Corporation with large NOL "LKYPon" <lkypon[at]aol.com> wrote: - quote - > Any ideas for a C-corporation with a huge NOL? It is unlike
Need more info. When was it formed? What kind of business> they will be getting any significant revenue. It's a > start-up with a lot of expenses, but no sales. did it do while generating such NOL? Is the owner(s) generating any income in another type of company?, etc. Mike Lewis, CPA << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#1
09-06-2004, 09:04 PM
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| Re: Corporation with large NOL lkypon[at]aol.com (LKYPon) wrote: - quote - > Any ideas for a C-corporation with a huge NOL? It is unlike > they will be getting any significant revenue. It's a > start-up with a lot of expenses, but no sales. It's probably not an NOL; it's probably start-up expenses, which are not deductible but must be capitalized. The corporation can elect on a timely filed return to amortize them over 60 months (IRC Sec. 195, I think). Otherwise they are not deductible until the corporation liquidates. Katie in San Diego The foregoing is intended for educational purposes only and does not constitute legal or professional advice. << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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09-06-2004, 08:06 PM
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| Re: Corporation with large NOL "LKYPon" <lkypon[at]aol.com> wrote: - quote - > Any ideas for a C-corporation with a huge NOL? It is unlike
Can you provide just a few more details? Seriously, there's> they will be getting any significant revenue. It's a > start-up with a lot of expenses, but no sales. not much an NOL can do inside a corporation unless there is income to offset it. -- David M. Woods, EA, ChFC, CLU Woods Financial Services Norwood, MA 02062 www.woods-financial.com << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
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#-1
09-01-2004, 11:58 PM
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| Corporation with large NOL Any ideas for a C-corporation with a huge NOL? It is unlike they will be getting any significant revenue. It's a start-up with a lot of expenses, but no sales. << -------------------------------------------------> << The Charter and the Guidelines for submitting > << messages to this newsgroup are at www.asktax.org > << -------------------------------------------------> |
| Tags |
| corporation, large, nol |
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