Arkansas Administrative Code
Agency 006 - Department of Finance and Administration
Division 05 - Division of Revenues
1998-1 - Comprehensive Corporation Income Tax Regulations
Rule 26-51-427 - DEDUCTIONS - NET OPERATING LOSS (NOL)
Rule 1.26-51-427(3)(C) - NOL Carryover Due to Merger
Universal Citation: AR Admin Rules 1.26-51-427(3)(C)
Current through Register Vol. 49, No. 9, September, 2024
In the case of a merger between two corporations that are owned by the same entity and that same entity owns at least 80% of the voting stock of each corporation, the formula for establishing that the assets of the merged corporation (that is, the corporation going out of existence) are still producing income is as follows:
Rule The carryover losses will be allowed only in those cases where the assets of the corporation going out of existence earn sufficient profits apportionable to Arkansas under § 26-51-701 et seq in the post-merger period to absorb the carryover losses claimed by the surviving corporation
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