A corporation may need a Sec. 382 Study if it has net operating losses (NOLs) or other tax attributes it may use, either now or in the future. For many corporations, these attributes are the largest tax assets on the corporation's financials and there is an expectation that the corporation will be able to benefit from these attributes in the future. Section 382 can significantly limit a corporation's ability to use its NOLs or other tax attributes. Many common corporate events can trigger the application of the limitations in Sec. 382.

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