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linda1

02/08/19 10:26 AM

#19580 RE: TigerInTheStreet #19270

No it is not clear that Holdco will receive zero
of the NOLs. There is language in the
APA that talks about the transfer of NOLs/Tax
Attributes to Holdco if the sales of assets
qualify as a Tax Reorganization.

The 363 Sale approved yesterday includes the
rights to the Sears’ Trademarks/Name.
So if SHC emerges from Bankruptcy as a
Reorganized Company it may have to drop
the Sears and change its name.