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Sunday, December 02, 2012 12:22:18 PM
The following lines are probably the most important, concrete, verificable and official information we have had since all this mess started 4 years ago.
From 10 Q, see page 16
http://www.sec.gov/Archives/edgar/data/933136/000119312512344418/d392232dex995.htm
On March 19, 2012, WMIHC emerged from bankruptcy. Prior to emergence, WMI abandoned the stock of WMB, thereby generating a worthless stock deduction of approximately $8.37 billion which gives rise to an NOL for the current year. Under Section 382 of the Internal Revenue Code, and based on our analysis, we believe that the Company experienced an “ownership change” (generally defined as a greater than 50 percent change (by value) in our equity ownership over a three-year period) on March 19, 2012, and our ability to use our pre-change of control NOLs and other pre-change tax attributes against our post-change income was limited. The Section 382 limitation is applied annually so as to limit the use of our pre-change NOLs to an amount that generally equals the value of our stock immediately before the ownership change multiplied by a designated federal long-term tax-exempt rate. Due to applicable limitations under IRC Section 382 and a reduction of tax attributes due to cancellation of indebtedness, a portion of these NOLs were limited and will expire unused. We believe the total available and utilizable NOL carry forward at March 19, 2012 is expected to be approximately $5.96 billion. These NOLs will begin to expire in 2030. The Company’s ability to utilize the NOLs or realize any benefits related to the NOLs is subject to a number of risks.
Let´s see a few words from that paragraph
“worthless stock deduction of approximately $8.37 billion ” …
I think that we ( as a company or corporation) had stock in WMBank, and before the abandonment, that stock's value was X.
Then when it became worthless we abandoned it and we had a stock loss of X (that loss will be ordinary loss or not (OL or not) depending on the law and on the IRS) which generates a worthless stock deduction of 0,35X ( being the deduction a net tax advantage)
I think that in our case the worthless stock deduction was 8,37 Billion and the amount of stock abandoned was 23,914 Billion, I mean the loss we had abandoning the stock was 23,914 Billion and the deduction ( it generated) was 23,914*0,35 = 8,37 Billion ( being the deduction a net tax advantage)
I also think that in our case ( according to the law and the IRS) the loss (and also the deduction and the net tax advantage) was ordinary, which is paramount for the potential buyer because it can be used to compensate ordinary ( and not specific) gains
“……which gives rise to an NOL for the current year” …
different to
“We believe the total available and utilizable NOL carry forward at March 19, 2012 is expected to be approximately $5.96 billion”…
Catz, do you think the 8,37 Billion deduction are a net tax advantage?
Are the 5,96 Billion (NOL carry forward ) another (and different) tax advantage we have to add to the 8,37 Billion (NOL for the current year)?
Is the net tax advantage from the 5,96 Billion (5,96 * 0,35) 2,086 Billion?
Is our total net tax advantage 8,37 Billion + 2,086 Billion, this is 10,456 Billion?
Your imput would be really very appreciated,
Thanks in advance
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