~ Well, ... Close But Not Quite ~
On 03/16/2012 ... as agreed upon, by all parties, as well as Judge Walrath, and Just ahead of Plan 7s Implementation Date of 03/19/2012, ... again, as agreed upon, WMI Released the Equity Interest, in its seized Bank, WMB (Filing # 9901), ...
The Bank WMB Itself, in its entirety, ... WAS NOT ... released by WMI, ... due to the fact(s) that, ... the FDIC had not yet finalized the Actual WMB Receivership, ... As Well As, there was continuing, open, and ongoing unsettled litigation, still going on in Judge Collyers Court in D.C. ...
So per the Original WMI Holdings Corp(s), First 10-Q Released for the period ending 12/31/2012 (it was not a full year, so this was originally filed as a Q) ... (now mysteriously changed to a K), ... the number considerations reported were initially Static, ... as they were separately reported in the details screens, there was an $8.37 Capital Loss Allowance, ... as well as additionally, a 35% Tax Ratio NOL (Net Operating Loss), A Tax allowance that would also be a consideration against $5.97 Billion Dollars ... or in hard values, ... a potential NOL Tax Benefit of $5.97 Billion Xs 35% or against a possible static allowance of some $2 Biilion Dollars in IRS Tax Benefit, against the newly reorganized companies potential positive earnings ...
So, ... in each of the WMIH SEC financial reporting periods, ... WMIH-Corp has reported a dribble of Earnings, using a literal dribble of the Tax Benefit, ... and to date, WMIH-Corp, has not reported the actual payment of ? or need to pay, ... any tax, ...
... So Today, Present Tense ... Five Issues That I Believe Are Important, ...
First: the WMIH-Corp NOLs Are Currently SEC Reported As ... Unrestricted, ... So they can be used in their entirety ? for this tax year 2018, ... or, obviously they could be used partially as time moves forward, ... however, I doubt there is a lot of Time Actually Left, ... please keep reading ...
Second: The Countries Tax Base has now been changed for Corporations in Tax Year 2018 ... remember tax Benefits are also static within the IRS current limitations ...
Third: Once the FDIC completes the Receivership and WMB is fully transitioned to JPMC, ... WMB, the bank, will be forever removed from the Original WMI Consolidated Taxing Group, and the tax loss benefit that WMB has been up to now, providing ?, ... will be gone ...
Fourth: It is my opinion, that the Courts scheduling order being extended into year 2019 was obviously done on purpose, ... and once Judge Walrath Rules On the CIC (Change in Control) issue, ... The FDIC will close and finalize the WMB Receivership, ... thus ending the WMB provided and allowable Tax benefit, ...
Fifth: So, the newly mergered company as disclosed by 2018 Years End 12/31/2018 ... is in a position to use the current and available ... Unrestricted ... Net Operating Loss NOLs, ... up to and until the FDIC closes the WMB Receivership, sometime in Tax Year 2019 ...
So, it is my opinion ? ... that the newly merged company ? ... will be in a position prior to 2018 tax years end, to utilize the lions share of roughly ... $5.97 Billion Xs 25% (ish), or roughly a $1.5 billion dollar (NOL), tax benefit, ... Meaning that the newly merged company will have been in a position to have taxable earnings in the neighborhood of roughly $12 Billion Dollars by 2018 Tax Years End, ... sshhhhh, no one is supposed to know, ... just not yet anyway ...
... The massive amount of Trusts and their actual servicing needs, can easily support these type of servicing numbers, ...
... Forget about any forfeited Tax benefit due to any ownership change issues, ... thats not going to happen ...
AZ
Aus I-Hub von AZCowboy
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