No it is not clear that Holdco will receive zero of the NOLs. There is language in the APA that talks about the transfer of NOLs/Tax Attributes to Holdco if the sales of assets qualify as a Tax Reorganization.
The 363 Sale approved yesterday includes the rights to the Sears’ Trademarks/Name. So if SHC emerges from Bankruptcy as a Reorganized Company it may have to drop the Sears and change its name.
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