APPLICATION OF NET OPERATING LOSS LIMITATIONS TO BANKRUPTCY REORGANIZATIONS.

SEC. 6277. APPLICATION OF NET OPERATING LOSS LIMITATIONS TO BANKRUPTCY REORGANIZATIONS. (a) Time for Determining Whether Ownership Change Occurs.—Section 621 (f)(5) of the Tax Reform Act of 1986 is amended 102 STAT. 3754 by adding at the end thereof the following new sentence: “The determination as to whether an ownership change has occurred during the period beginning January 1, 1987, and ending on the final settlement of any reorganization or proceeding described in the preceding sentence shall be redetermined as of the time of such final settlement.” (b) Election To Have New Rules Apply.—Section 621(f)(5) of the Tax Reform Act of 1986 is amended by striking out “In” and inserting in lieu thereof “Unless the taxpayer elects not to have the provisions of this paragraph apply, in”. (c) Effective Date.—The amendments made by this section shall take effect as if included in section 621(f)(5) of the Tax Reform Act of 1986.