in a recent post, this was said:
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“ESL, we know, is a ‘qualified creditor’ of Sears,” so any stock it receives as part of the deal “would count positively towards satisfaction of the bankruptcy exception,” New York-based tax consultant Robert Willens told Bloomberg Tax in an email.
The proposal not only ensures that ESL will have access to Sears’ NOLs, but that the combined company won’t be “burdened” by the limitation under Section 382, he said.
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What makes anyone think the plan has changed. IMHO it has not.
SHLDQ Long and strong. GLTA"
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for the author, the "combined company" was the combination created when transform holdco purchased substantially all of the "go-forward" assets of shc.
that's the combination! it has already happened! holdco is just waiting for a private irs ruling or an opinion from his tax professionals. if expedited, that could take a couple of months. imo, that's a major reason the sale has yet to close.
the reference to a combined company is not a subtle reference to a future combination of holdco and what remains of "old sears".
