# Section 382 limitation

> Section 382 limitation — The annual cap on using pre-change NOLs and credits after an ownership change — a more-than-50-percentage-point increase in ownership by 5% shareholders over a rolling three-year testing period. The cap is the loss corporation's equity value immediately before the change times the IRS long-term tax-exempt rate; unused cap carries forward.

Source: https://lopifi.com/glossary/section-382-limitation
Part of: Lopifi — US GAAP books on autopilot, reviewed by a CPA (https://lopifi.com)

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**What is section 382 limitation?** In accounting, section 382 limitation means the annual cap on using pre-change NOLs and credits after an ownership change — a more-than-50-percentage-point increase in ownership by 5% shareholders over a rolling three-year testing period. The cap is the loss corporation's equity value immediately before the change times the IRS long-term tax-exempt rate; unused cap carries forward.

## Words this system refuses for it

- NOL expiry
- change of control alone

- **Category:** Tax
- **Specified in:** [Lexicon](https://lopifi.com/md/docs/domain/11-lexicon)
- **Related:** equity, period