Mariano owns all of Alpha Corporation, which owns 100% of Beta Corporation's single class of stock. On January 1, Alpha and Beta Corporations report a consolidated NOL carryover from prior years. What is the maximum percentage of Alpha Corporation's single class of stock that Mariano can sell to a single shareholder without triggering the Sec. 382 loss limitation?

Question

Quizplus · Accepted Answer

Under Sec. 382, a change in ownership occurs if there is a more than 50% change in stock ownership by 5% shareholders. Mariano can sell up to 50% without triggering the limitation.

Mariano Owns All of Alpha Corporation, Which Owns 100% of Beta