In a year in which an ownership change occurs for a corporation, the NOL carryforward is limited not only by the § 382 annual limitation but also by the percentage of the year remaining.

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When a corporation undergoes an ownership change, the amount of its net operating loss (NOL) carryforward that can be used in the year of the change is limited by both the § 382 limitation and the proportion of the year remaining after the ownership change occurs. This ensures that the NOL deduction is prorated for the portion of the year after the ownership change.

In a Year in Which an Ownership Change Occurs for a Corporation