Tax Services

Section 382

Limitations on tax attribute carryforwards following an acquisition or ownership change can create a big impact on the tax liability for C corporations. Accurately measuring the net effect of a specific business or equity transaction in terms of Section 382 ownership changes and limitations requires careful analysis based on historical and current-year data.

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Helping You Find the Answers You Need Before It’s Too Late

Will your next business decision bring unanticipated financial consequences? Have shareholder activities or convertible debt instruments already triggered Section 382 provisions for your business, unbeknownst to company leaders? Without a full understanding of how Section 382 limitations could affect your tax picture going forward, you can’t gauge the true value in a prospective business transaction or determine the hidden risks in a change to your company’s equity structure.

Don’t take a step you might come to regret; let us help you evaluate the potential tax consequences of an acquisition or ownership change so you can see where you’re going — and where you’ve been. Our experienced tax advisors give you the visibility you need with comprehensive, customized Section 382 studies and analysis that help you identify Section 382 thresholds so you can avoid costly mistakes.

Experts
Tim Guderian - Partner, Tax - San Jose CA | Armanino
Partner
Tim has 25 years of public accounting experience, including experience at a Big Four firm.

San Jose, CA
Daniel Rife - Tax | Armanino
Senior Manager
Dan has been providing tax expertise to a wide range of clients since 1999 He is a leader on the Section 382 team, and ...
Resources
News & Insights
Tllray 382
Case Study
Here’s how one loss corporation was able to offset $64M of taxable income with help from our Section 382 experts.

March 14, 2022
Company Claims CNOL Carryback Under CARES Act Provision, Receives $1.6M Tax Refund
Case Study
Armanino’s 382 experts’ proactive analysis of new eligibility rules nets big return for private equity firm.

February 22, 2021
Case Studies
Case Study
By working with our tax advisor who was well-versed in Section 382, the company saved millions.

May 18, 2020
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