In addition to what has been posted:
- As you stated, in general, C corporation NOL's cannot be used during the S election period
- An exception to this, is if the S corporation is subject to the BIG (built-in gains tax).
- If the S corporation is subject to the BIG, C corp net operating losses can be used to offset the built-in gain; which reduces any BIG tax. IRC 1374(b)(2)
- Additionally, if the S status is lost or terminated in the middle of a tax year, the short S period and short C period is treated as one year; essentially the short S year is disregarded when determining carryover period years. IRC 1362(e)(6)(A)
*A reminder that posts in a forum such as this do not constitute tax advice.
Also keep in mind the date of replies, as tax law changes.
