A present value analysis is beneficial when valuing tax attributes limited by the § 382 limitation.

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Present value analysis can help assess the value of tax attributes that are restricted by the § 382 limitation, which limits the amount of net operating losses (NOLs) and other tax attributes that can be used by a company in a taxable year if it has undergone an ownership change. Valuing these attributes requires accounting for limitations on their use, and present value analysis can help estimate the future value of the tax benefits generated by the attributes based on their expected future use.

A Present Value Analysis Is Beneficial When Valuing Tax Attributes