actually, the "G" reorganization was done for the benefit of transform holdco so that they would be able to utilize the nols and tax credits.
the only way the nols would go back to shc would be if lampert is unable to secure a favorable irs ruling in which case lampert could reject them.
if lampert could not get a favorable irs ruling and the nols reverted to shc, i'm not sure shc would be able to utilize them because i think in order for shc to be able to then utilize them, shc would have to have a substantial portion of the business(es) which originally gave rise to the nols in the first place.
since substantially all of the go-forward assets of shc's subsidiaries were sold to transform holdco, not exactly sure what assets are left which (1) gave rise to the nols in the first place, and (2) which are still being held by shc around which shc could reorganize.
additionally, regardless of the nols, shc and its debtor subsidiaries are required to wind down and liquidate within three taxable years of the closing which occurred on february 11, 2019.
it possible if the nols were rejected by lampert and went back to shc they might be worthless.
