and be cautious, i used taxcarryforwards, and not nols.
wmi made in the month from 1/1/2008 until the seizure at the 9/25/2008 capital conributions to wmb with a value of 6,5 bio or 6500 mio (look at the examinerreport, if you don`t believe it).
wmi had at the day of the seizure a loss of 26 bio or 26000 mio (the book value of wmb, which was taken away by fdic/otc). this is a capital loss, and has nothing to do, when and if the wmi abandoned wmb shares.
thats together 32,5 bio (check it with the examinerreport).
now wmi asked the irs, to grant them in an private letter ruling, that this capital losses could be used as ordinary losses, and the irs granted it. there are some advantages in ordinary losses aka nols, you can carryforward it 20 years and you can exchange it with ordinary gains. that`s important, because if the irs would not have granted the wmi this private letter ruling, the wmi would have to use some or all of the wmb losses (about 14,5 bio) for the taxrefunds (about 12,5 bio).
now, wmb/fdic/jpm couldn`t use the operating losses from the first three quarters 2008, if wmi did use them, so wmi had to reduce the amount of 32,5 bio or 32500 mio by this wmb nols (only then fdic/jpm could use them for themself) of about 14,5 bio or 14500 mio.
32,5 - 14,5 are 18 bio (looks like we are close to your 17,7 bio, sgt, or not?).
and this 18 bio or 18000 mio had to be reduced by the amount used for the taxrefunds, that would be 4,5 / 0,35 = 12,5 bio and about 5,5 or 5500 mio.
check this number with rosens por, there it is 5450 mio or 5,45 bio.
now let`s look at the time between the seizure and the effective date (effective date is the date wmi leaving bancrupcy and becoming wmih).
if you look at the mors from oktober 2008 and december 2011, you can see a difference of about 0,9 bio or 900 mio.
a part is the operating loss of wmi (rosens fees, maybe we will see some brainwashing and whitewashing from wal rat and get some millions back, for the liquidating trust, lol), in my guess about 500 mio, and a part must be capital losses from selling assets of wmi investment.
so, a day before the effective date we should have the 5500 nols preseizture, and nols of 500 mio and capital losses of 400 mio for wmi.
now, with the effective date some gifts from wmi to jpm and fdic takes place.
3900 mio for the tps, 3100 mio for the taxrefundparts, maybe 5400 mio for the bolicoli, and i guess about 700 mio for the dimeqs, visa, windpower aso.
that`s about 13100 mio or 13,1 bio capital transfer to fdic/jpm and imo also 13,1 bio capital losses for wmi.
so, at the effective date wmi should have 13500 mio or 13,5 bio capital losses and 6000 mio or 6,0 bio nols (ordinary losses).
if, a big if, the 14,5 bio or 14500 mio of wmb nols can not be used by jpm (imo you can bet on it, they will use it), this amount could be added. but i will not do it, i guess, 10 minutes after wmi abandoned the wmb shares to fdic (yes, they did not burn them, they did not push the down the wc, they abandoned them to wmb aka fdic) the fdic sold them for 1,8 dollar to jpm. and jpm will use them, and get additional 5 bio loot.
there will be another 400 mio capital transfer from wmi to jpm when the remaining taxrefunds of 500 mio will come in.
thats all in all about 13,9 bio capital losses and 6,0 bio ordinary losses as taxcarryforwards at the time, the next taxdeclaration is due. all in my opinion, i`m not a taxaccountant. |
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