1627571
I own 80% stock in both corporations.
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You can't just move NOL's from company to company.
This issue is one that is best handled with competent tax professional(s). I say plural as you will need to involve legal counsel and a tax professional.
There are rules that prevent the shifting of NOLs, however, those apply only when there has been an owner or equity shift of more than 50 percent over a 3 year period. Based on the limited facts, you are currently below that threshold as you indicate you own 80% of both companies.
However, you can only accomplish what you want through an acquisition or a merger; hence the need to involve legal counsel.
You can't just move NOL's from company to company.
This issue is one that is best handled with competent tax professional(s). I say plural as you will need to involve legal counsel and a tax professional.
There are rules that prevent the shifting of NOLs, however, those apply only when there has been an owner or equity shift of more than 50 percent over a 3 year period. Based on the limited facts, you are currently below that threshold as you indicate you own 80% of both companies.
However, you can only accomplish what you want through an acquisition or a merger; hence the need to involve legal counsel.
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