Keep_trying, this is the "dumbed down version" from my memory.
. They can apply TLCF to the earnings generated by the acquired property. This is limited to so much a year.
. They can mark up the IP prior to purchase and use the TLCF to offset that. But that is clearly limited to the tax gain on the value of the deal over asset value.
There is a huge body of law on this. And many details. But the one thing that is certain is that they can not buy a shell and apply those TLCFs to their earnings.