Trenwick Group, Ltd.(fka TWKGQ)

[lifegear]

"Sec. 382, however, limits the use of NOL carry-forward losses, and certain other tax attributes
by the surviving corporation. If the pre-transaction shareholders of the loss corporation do not
own at least 50% of the fully diluted equity (other than non-voting, non-participating preferred
stock) of the surviving entity as applied under the rules of Sec. 382, the use of the NOLs by
the surviving corporation are limited to the fair market value of the merged entity immediately
before the transaction multiplied by the highest long-term tax-exempt bond rate applicable for
any of the 3 months before the transaction."

http://www.ibfd.org/portal/pdf/Excerpt_MergersandAcquisitions.pdf