Contact UsHas anyone had experience dealing with the conversion of NYS NOLs from a pre-apportionment to a post-apportionment basis for NOLs generated on or before 12/31/2014 (for a calendar year taxpayer)? My issue is how to apply Section 382 limits in converting these historical NOLs to the PNOL.
The statute seems to state that any NYS NOLs that have not freed up under Section 382 by 12/31/2014 will be lost even if they would have freed up in subsequent years that would be prior to expiration. However, this is not clearly outlined in the law, so I am wondering if there has been any clarification on this topic provided by the state.
