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Re: JusticeWillWin post# 445935

Friday, 02/12/2016 11:01:54 AM

Friday, February 12, 2016 11:01:54 AM

Post# of 729793
It shouldn't nullify WMIH's NOLs. It would nullify or limit the acquired NOLs of something like KFN or MFF (IRC 382).

If KFN or MFF's NOLs are greater than WMIH NOL's ($6B) then it would be insane to trigger IRC 382 on KFN or MFF NOLs.

See post 443905 when a hypothetical of MFF was discussed. Specifically point 2B.

Post 443983 for another.

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If KKR sold an entity like KFN or MFF for greater than it's purchase price, it should get around the restrictions as well.

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Also only works because WMIH Corp is a publicly traded company and not a subsidiary of any other company.
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