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Old 10-13-2016, 03:25 PM   #1
golfeveryday
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C Corp with NOL

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3 c-corps all owned equally 50/50 by the two same unrelated individuals. C corp#1 is barely profitable. C Corp #2 and #3 are much more profitable. C Corp#1 has a very large NOL that it doesn't use very fast due to lower profit. Is there a way to re organize these corporations to take advantage of the NOL and have the profits of corp #2 and #3 use the NOL while also maintaining the separation of liability that the 3 current entities have?
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Old 12-11-2016, 08:20 PM   #2
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Look at the rules regarding Separate Return Limitations (SURLY), section 482 regarding transactions between related corporations, as well as the sections regarding mergers, acquisitions, and reorganizations (1500s in the tax code. A creative tax attorney may be able to find a way to accomplish what you want, but I doubt it.
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