In a transaction to which IRC section 381(a) applies, the acquiring corporation shall succeed to the balance of the PNOLC subtraction allotments and unused PNOLC subtraction carryforward of the distributor or transferor corporation, subject to the same restrictions and limitations on the use of the PNOLC subtraction allotments and unused PNOLC subtraction carryforward to which the distributor or transferor corporation was subject.
N.Y. Comp. Codes R. & Regs. Tit. 20 § 3-8.10