The Treasury Department and IRS issued final and temporary regulations under Section 382, affecting loss corporations whose stock is or was acquired by the Department of the Treasury (Treasury) pursuant to certain programs under the Emergency Economic Stabilization Act of 2008 (EESA). Section 382 limits the ability of a corporation to use net operating losses to offset income after a change in ownership. Treasury and the IRS were concerned that October 2013 changes to the Section 382 regulations rendered inoperative the provisions of Notice 2010-2, which was intended to prevent companies whose stock was acquired by Treasury from having a change in ownership when Treasury sold its holdings to public shareholders. These regulations ensure that this protection will be effective under the current rules.
The regulations can be accessed here.