preacquisition loss
Defined in 1 place of the United States Code.
In the case of a corporation with a net unrealized built-in loss, the term “preacquisition loss” includes any recognized built-in loss.
Source
- 1994–present26 U.S.C. § 384Internal Revenue Code · Limitation on use of preacquisition losses to offset built-in gains · for purposes of this section
The term “preacquisition loss” means—
(i) any net operating loss carryforward to the taxable year in which the acquisition date occurs, and
(ii) any net operating loss for the taxable year in which the acquisition date occurs to the extent such loss is allocable to the period in such year on or before the acquisition date.
Source
- 201326 U.S.C. § 384Internal Revenue Code · Limitation on use of preacquisition losses to offset built-in gains · for purposes of this section
The term "preacquisition loss" means—
(i) any net operating loss carryforward to the taxable year in which the acquisition date occurs, and
(ii) any net operating loss for the taxable year in which the acquisition date occurs to the extent such loss is allocable to the period in such year on or before the acquisition date.
Except as provided in regulations, the net operating loss shall, for purposes of clause (ii), be allocated ratably to each day in the year.
Source
- 1994–present26 U.S.C. § 384Internal Revenue Code · Limitation on use of preacquisition losses to offset built-in gains · for purposes of this section