They can't circumvent the IRS Code on buying and selling NOLs - after the BioAmber assets were liquidated - the buyer didn't want the contracts or NOLs.
If as a few think/don't understand about buying NOLs - if they are so valuable the buyer didn't want to purchase them - now they don't have any value.
According to Rule 382 of the IRS Code - BioAmber has to change ownership - but BioAmber liquidated their assets in a bankruptcy.
"Congress enacted Section 382 to prevent a corporation with a large taxable income from purchasing a company with net operating losses (NOL) carryforwards and using those “acquired” NOLs to offset income. Provisions of this section apply when there is a change in the ownership of a C corporation with accumulated NOL carryforwards."
IG
"Are you gonna pull those pistols or whistle Dixie?"