Estimated Cost - gain of $6,977 million* Elimination of IRC § 382 Limitations On NOL Carryovers In Certain EESA Restructurings Notwithstanding the finding that Notice 2008-83 was invalid, Congress enacted new IRC § 382(n)(l), which provides that the NOL limitation will not apply to a change in ownership resulting from a restructuring plan of a taxpayer that is (i) required under a loan agreement or commitment for a line of credit entered into with the Treasury… [read post]