Mariano Owns All of Alpha Corporation, Which Owns 100% of Beta

question 83

Multiple Choice

Mariano owns all of Alpha Corporation, which owns 100% of Beta Corporation's single class of stock. On January 1, Alpha and Beta Corporations report a consolidated NOL carryover from prior years. What is the maximum percentage of Alpha Corporation's single class of stock that Mariano can sell to a single shareholder without triggering the Sec. 382 loss limitation?

• A)0%
• B)50%
• C)75%
• D)80%

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Definitions:

Pooled Resources

The amalgamation of assets or capital from multiple sources or individuals for a common purpose, often to achieve a goal that would be difficult to achieve individually.

Tax Advantages

Financial benefits that apply to certain investments or accounts, which can reduce the amount of tax owed to the government.

Right of First Refusal

A contractual right that gives its holder the option to enter a business transaction with the owner of something, before the owner is entitled to enter into that transaction with a third party.

Limited Liability

A form of legal protection for shareholders and owners that limits their losses to the amount of investment in the company, protecting personal assets from company debts and liabilities.