Lehman Brothers Financial SA (LEHNQ)

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As of April 4, 2024, the Company recorded an
estimate of $8.7 million for potential pre- and post-
petition amounts owed to federal, state, local and
international taxing authorities, net of expected refund
claims. Between January 1, 2024, and April 4, 2024,
the Company’s tax payable decreased by $1 million as
a result of global tax audit progress

Quarterly Financial Report as of April 4, 2024 (Unaudited)
Page 16
Note 5 – Taxes Payable
Taxes payable is an estimate of tax liabilities, net of
the estimated impact of any refund claims, deposits,
and net operating losses (“NOL”). Taxes payable
have been allocated among the members of the LBHI
Tax Group pursuant to the Debtor Allocation
Agreement. The Debtor Allocation Agreement,
which became effective on the Effective Date,
addresses the relationship among the Debtors and
certain Affiliates with respect to consolidated
federal/combined state/local income taxes for pre-
petition and post-petition years.
As of April 4, 2024, the Company recorded an
estimate of $8.7 million for potential pre- and post-
petition amounts owed to federal, state, local and
international taxing authorities, net of expected refund
claims. Between January 1, 2024, and April 4, 2024,
the Company’s tax payable decreased by $1 million as
a result of global tax audit progress.
Net Operating Losses
The NOLs of the LBHI Tax Group (including LBHI-
Controlled Affiliates) are subject to audit and
adjustment by the IRS and primarily expire in or
about 2028. Substantially all of the LBHI Tax
Group’s current consolidated net operating loss
carryovers are attributable to the Debtor. The Plan
provides for an orderly liquidation of the Debtors. As
previously disclosed in the Company’s Quarterly
Financial Report as of March 31, 2012 [Docket No.
29731], the LBHI Tax Group received a private letter
ruling from the IRS in connection with the Plan going
effective that stated (i) the liquidation of the Debtor
for U.S. federal income tax purposes may occur over
an extended period, and (ii) the reduction of the
LBHI Tax Group’s NOLs as a result of the discharge
of debt pursuant to the Plan generally would not
occur until completion of the liquidation.
In January 2020, the Company received a
supplemental IRS ruling extending the original ruling
relating to the Company’s liquidation. All remaining
Debtor NOLs not previously utilized to absorb
taxable income of the LBHI Tax Group are expected
to be fully utilized to offset income resulting from the
discharge of debt on the final date of liquidation of
LBHI.
08-13555-mg Doc 61667 Filed 06/12/24 Entered 06/12/24 16:13:38 Main Document
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