L Corp has business assets worth $8 million and NOL carry forwards of $1 million expiring in 14 years and $2 million expiring in 15 years, and 100% of L stock is worth $10 million. L also has $1 million of excess cash in the valuation above. If L sells its business assets in the U.S. without recognizes gain or loss, L can invest its $8 million liquid assets in US Treasury Bonds earning 10% so that L can use the NOLs at the rate of $800,000 per year. The long term tax-exempt rate is 8%.

A) What will the 382 limitation be if an ownership change occurs with respect to Ls stock?

B) What is L has minimal assets instead of just a $1 million of excess cash, 100% of its stock is worth $1 million, would your answer above change?