Extract to table

Specifically, Section 382(a) provides that if an ownership change occurs with respect to a loss corporation, the amount of the corporation's taxable income for any post-change year which may be offset by pre-change losses shall not exceed the Section 382 Limitation

Conversely, if the exchanged indebtedness was privately placed and held by a limited number of institutional investors, the individual creditors must be separately analyzed to determine whether any single creditor will hold 5% or more of the loss corporation's stock after the exchange

5% common equity allocation must be analyzed individually