AMT consequences of an ownership change.
The Tax Adviser › Vol. 40 Nbr. 9, September 2009
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Summary
Alternative minimum tax
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AMT consequences of an ownership change.
In the current economic environment, there will likely be more ownership changes of corporations with built-in losses (BILs). Whereas most tax planning routinely contemplates the impact of the Sec. 382 limitation on the use of a corporation's net unrealized built-in losses (NUBILs) following an ownership change, the corresponding impact of Sec. 56(g)(4)(G) for adjusted current earnings (ACE) is often overlooked and may have a significantly different effect than Sec. 382. Under Sec. 382, tax basis in assets is restricted only when an actual loss is recognized, whereas under Sec....
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