Table:
|  | 2019 | 2018 |
| --- | --- | --- |
| Deferred tax assets: |  |  |
| Stock-based compensation | $2,646 | $3,067 |
| Net operating loss carryforwards | 9,419 | 8,568 |
| Research credit carryforwards | 5,570 | 3,890 |
| Intangibles | 58 | — |
| Other, net | 90 | 354 |
| Total deferred assets | 17,783 | 15,879 |
| Deferred tax liabilities: |  |  |
| Intangibles | — | (181) |
| Foreign deferred liabilities | (5,811) | (8,032) |
| Net deferred tax asset | 11,972 | 7,666 |
| Valuation allowance for net deferred tax assets | (931) | (472) |
| Net deferred tax asset | $11,041 | $7,194 |
Paragraphs:
Deferred Income Tax Assets and Liabilities
Significant components of the Company’s net deferred tax assets and liabilities as of September 30, 2019 and 2018 are as follows(amounts shown in thousands):
The net change in the total valuation allowance for the fiscal years ended September 30, 2019 and 2018 was an increase of $0.5 million and an increase of $0.4 million, respectively. In assessing the realizability of deferred tax assets, the Company considers whether it is more likely than not that some portion or all of the deferred tax assets will not be realized. The ultimate realization of deferred tax assets is dependent upon the generation of future taxable income during periods in which those temporary differences become deductible. The Company considers projected future taxable income and planning strategies in making this assessment. Based on the level of historical operating results and the projections for future taxable income, the Company has determined that it is more likely than not that the deferred tax assets may be realized for all deferred tax assets with the exception of the net foreign deferred tax assets at Mitek Systems B.V.
As of September 30, 2019, the Company has available net operating loss carryforwards of $29.5 million for federal income tax purposes, of which $2.1 million were generated in the fiscal year ended September 30, 2019 and can be carried forward indefinitely under the Tax Cuts and Jobs Act. The remaining federal net operating loss of $27.4 million, which were generated prior to the fiscal year ended September 30, 2019, will start to expire in2032 if not utilized. The net operating losses for state purposes are $29.4 million and will begin to expire in2028. As of September 30, 2019, the Company has available federal research and development credit carryforwards, net of reserves, of $2.8 million. The federal research and development credits will start to expire in2027. As of September 30, 2019, the Company has available California research and development credit carryforwards, net of reserves, of $2.4 million, which do not expire.
Sections 382 and 383 of the Internal Revenue Code of 1986, as amended (the “IRC”) limit the utilization of tax attribute carryforwards that arise prior to certain cumulative changes in a corporation’s ownership. The Company has completed an IRC Section 382/383 analysis through March 31, 2017 and any identified ownership changes had no impact to the utilization of tax attribute carryforwards. Any future ownership changes may have an impact on the utilization of the tax attribute carryforwards.
Question:
Which laws limit the utilization of tax attribute carryforwards that arise prior to certain cumulative changes in a corporation’s ownership?
Answer: Sections 382 and 383 of the Internal Revenue Code of 1986