Mr Cooper Group Inc (COOP)

[Evintos]

Internal Revenue Code section 382 -

If you apply 382 limitations on the $1 Billion profit for 2016

$1,000,000,000 - $159,000,000 (annual limitation at 2.65% rate) = $841,000,000 taxable at state and federal corporate rates.

2016
$73,587,500 Delaware taxes owed.
$295,616,666.54 Federal taxes owed.
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$369,204,166.54 Total taxes owed for 2016 for $1B profit utilizing NOLs limited by section 382

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So for an acquiring company to effectively use NOLs using NOL carry forward - they would have to acquire and somehow sneak past the IRC section 269 scrutiny AND get around section 382 limitations.

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Last bit of section 382 that applies is 2 years of continuity. The acquired company must operate for 2 years (under old or new name) after being acquired otherwise the NOLs are reduced to 0.