Tuesday, October 02, 2012 2:15:20 AM
I did try my best to beat it into this board's head, that the NOL's were of the OL variety and had no restrictions. Some tried to knock me down for my comment, but this little tidbit proves what I was saying was entirely correct. I was a little off in the value of such, something got written off entirely after the BK started, because WMB had much more OL loss accumulated for WMI.
From 10-QA
Based on our analysis, we believe WMIHC experienced an ownership change under Section 382 of the Internal Revenue Code. Prior to emergence, WMI abandoned the stock of Washington Mutual Bank (“WMB”), thereby generating a worthless stock deduction of approximately $8.37 billion, which gives rise to a NOL for the current year. We believe that the total available and utilizable NOL carry forward at March 19, 2012 is expected to be approximately $5.96 billion and at June 30, 2012 there was no limit on the use of these NOLs. See Note 7: Federal Income Taxes and Item 1A. Risk Factors- Risks Related to WMIHC’s
Business
Bring on a really huge corporation that needs to offset a large amount of profits... NO RESTRICTIONS.
Look up my previous post on why the IRS in 2008 made a rule change for the benefit of an OL that is not restricted.. One example is when a Parent company of a bank that has the bank account for 80% or more of its total earnings loses the bank through receivership, the worthless stock deduction will become an Ordinary Loss (OL) that will have no restrictions for the acquiring party of the parent company.
This rule change was made to protect the shareholders of the parent company from huge losses and therefore when they are acquired they can get back some of the losses in said acquisition of parent. As I stated last year..
WMIH will acquired by a multi-billion dollar corporation who will want to use the "unrestricted" OL of the NOL variety to offset the profits they have generated over the year. Companies like Apple, Google, Exxon-Mobil, Not BP (they lost too much in Gulf spill) etc.. OL's are written directly off the balance sheet (like expenses)
Let's say you made
4 Billion and you acquire a company that has a 2 Billion OL
You now have a taxable income of 2 Billion at 35% that translates to 700 Million saved by acquiring the company with the 2 Billion OL. If you paid 25% for the company you get what they have and you save 350Million in the process.
OUR OL/NOL is 6 Billion X 35% = 2.1 Billion discounted 20% = 1.68 Billion/200M = roughly $8 pps. You issue stock in your company equivalent to and the transaction is done and you get the OL/NOL for a direct write-off which benefits all shareholders in your corp.
Now all we do is wait for Dec 31, to see if the BOD is on pace to get acquired. I hope you guys enjoyed this awesome summer, I know I have. My Ducks are undefeated and we (shareholders) are waiting for the announcement of being acquired. Go back and read my posts on the 382 (D) I think, rule change for NOL into OL by the IRS. Or just search my posts. I would post it, but I am just too damn busy right now.
Did we get released from THJMW's court yet?
I know she had command and control still.
Take Care
~Don~
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