Neil Gulati
Level 2
03-06-2019
12:28 PM
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Question - Do the Section 382 limitation on NOL deduction of the US Co. applies to the following facts (My thinking is that it probably does not):
US Corporation (US Co.) owned 100% by a Foreign Corp. (Sub 1) which is owned 100% by another Foreign Corp.(Parent Co.) .
Sub 1 transfers its 100% ownership of the US Co. to another Foreign Corp (Sub 2) which is also owned 100% by same Parent Co.
US Co. files its stand alone US Corp. income tax return and will continue to do so.
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