Followers | 73 |
Posts | 8833 |
Boards Moderated | 0 |
Alias Born | 06/05/2014 |
![](https://investorshub.advfn.com/uicon/482550.png?cb=1487848485)
Tuesday, December 09, 2014 4:23:46 PM
http://www.mondaq.com/unitedstates/x/286506/Corporate+Tax/IRS+Issues+Favorable+Final+Section+382+Regulations+On+Small+Shareholders+Might+Be+Time+To+Revisit+Your+382+Study
2 Generally, the "testing period" for any testing date is the three-year period ending on the testing date. Once an ownership change occurs, the three-year testing period is reset and a new testing period begins. See Treas. Reg. Section 1.382-2T(d)(1).
Contrary to your statement here ?!?
[...]
Two items, when you can, would expand your work product and understanding. First is the concept of "value" versus "share count" in the calculation of the % increases should KKR exercise the warrants. This supports your theory component regarding the disadvantages of the rapid rise in PPS in December 2013 on another front (aside from the immediate tax consequences on exercising the warrants as ordinary income on the gain over the warrant exercise price). Second, again, is the 3-year rule. Specifically, there is no beginning or ending period of such, it is a rolling application any time there is a change in the 5%er (increases only). The trigger for testing dates can happen over and over, and there is no 'clearance once one testing period has been passed and met if there is another change in 5%er.
[...]
and also here:
http://investorshub.advfn.com/boards/read_msg.aspx?message_id=107211367
It does not. The 3-year change of control rule is a "rolling 3-year period" that simply does not end. If, at any time during any 3-year period, those that own 5% or more of WMIH, including new parties that aggregate 5% or more, all added together represent an INCREASE OF 50%, then another "ownership change would be triggered and the NOLs would be subject to IRC 382 reduced to a calculation of valuation and rate application. The numbers a puny compared to the $6B unrestricted NOL.
Recent COOP News
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/30/2024 08:07:34 PM
- Form 8-K - Current report • Edgar (US Regulatory) • 05/24/2024 08:36:48 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:33:25 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:28:46 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:26:19 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:24:11 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:22:07 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:19:44 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/24/2024 08:17:44 PM
- Xome Democratizes Real Estate with Launch of DIY Sales Platform, No Agent Required • Business Wire • 05/22/2024 01:00:00 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/15/2024 10:47:32 PM
- Form DEFA14A - Additional definitive proxy soliciting materials and Rule 14(a)(12) material • Edgar (US Regulatory) • 05/15/2024 12:11:30 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 05/10/2024 12:12:48 AM
- Form 144 - Report of proposed sale of securities • Edgar (US Regulatory) • 05/07/2024 08:22:09 PM
- Mr. Cooper Group Reports First Quarter 2024 Results • Business Wire • 04/24/2024 11:00:00 AM
- Mr. Cooper Group Announces Two New Senior Leaders • Business Wire • 04/23/2024 01:00:00 PM
- Mr. Cooper Group Inc. to Discuss First Quarter 2024 Financial Results on April 24, 2024 • Business Wire • 04/05/2024 03:37:00 AM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 03/11/2024 09:34:36 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 03/04/2024 11:05:39 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 03/04/2024 11:04:15 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 03/04/2024 11:03:04 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 03/04/2024 11:01:41 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 03/04/2024 10:59:25 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 02/26/2024 09:28:25 PM
- Form 4 - Statement of changes in beneficial ownership of securities • Edgar (US Regulatory) • 02/14/2024 09:15:59 PM
Freedom Holdings Corporate Update; Announces Management Has Signed Letter of Intent • FHLD • Jul 3, 2024 9:00 AM
EWRC's 21 Moves Gaming Studios Moves to SONY Pictures Studios and Green Lights Development of a Third Upcoming Game • EWRC • Jul 2, 2024 8:00 AM
BNCM and DELEX Healthcare Group Announce Strategic Merger to Drive Expansion and Growth • BNCM • Jul 2, 2024 7:19 AM
NUBURU Announces Upcoming TV Interview Featuring CEO Brian Knaley on Fox Business, Bloomberg TV, and Newsmax TV as Sponsored Programming • BURU • Jul 1, 2024 1:57 PM
Mass Megawatts Announces $220,500 Debt Cancellation Agreement to Improve Financing and Sales of a New Product to be Announced on July 11 • MMMW • Jun 28, 2024 7:30 AM
VAYK Exited Caribbean Investments for $320,000 Profit • VAYK • Jun 27, 2024 9:00 AM