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| Alias Born | 03/26/2018 |
Tuesday, March 26, 2019 11:44:42 PM
Read up on 363 sales and how they can be structured as a tax-free reorganization under IRC Section 368;
Section 382 (Change of ownership NOL limitation) does not apply to a 368 restructure because of continuity of interest of existing target corporation shareholders.
Assets...check
Executory contracts...check
NOLs...check
Plans & permits for second commercial plant...check
Financing from LCY/KKR...check
All this from a pre-packaged stalking horse sale...brilliant.
Section 382 (Change of ownership NOL limitation) does not apply to a 368 restructure because of continuity of interest of existing target corporation shareholders.
Assets...check
Executory contracts...check
NOLs...check
Plans & permits for second commercial plant...check
Financing from LCY/KKR...check
All this from a pre-packaged stalking horse sale...brilliant.
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