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Er könnte dazu auch im soeben erschienen Quartalsbericht eine Passage lesen:
We, together with our subsidiaries, may not be able to fully utilize our net operating loss and other tax carry forwards.
As of December 31, 2011, WMIHC and its subsidiaries had U.S. Federal net operating loss carry forwards of approximately $14 million, that if unused, will begin to expire in 2030. We have projected that WMIHC and its subsidiaries will have a NOL for 2012 of approximately $7.532 billion of which approximately $5.906 billion, will be allocated to that portion of 2012 after the ownership change described below. Both WMIHC and WMMRC have established valuation allowances for these deferred tax assets based on their assessments of the amounts of deferred tax assets that are more-likely-than-not realizable.
On March 19, 2012, we believe that WMIHC and its subsidiaries experienced an “ownership change” within the meaning of Sections 382 and 383 of the U.S. Internal Revenue Code of 1986, as amended (the “Code”). An ownership change is generally defined as a more than 50 percentage point increase in equity ownership by “5% shareholders” (as that term is defined for purposes of Sections 382 and 383 of the Code) in any three year period or since the last ownership change if such prior ownership change occurred within the prior three year period. As a result of the ownership change on March 19, 2012, the limitations on the use of pre-change losses and other carry forward tax attributes in Sections 382 and 383 of the Code apply and WMIHC and its subsidiaries will only be able to utilize a small portion of their NOL carry forwards from the years prior to 2012 and the portion of the NOL for 2012 allocable to the portion of the year prior to March 20, 2012. The utilization of the NOL for 2012 allocable to the portion of the year after March 19, 2012 and the NOLs from subsequent years should not be affected by the ownership change on March 19, 2012.
The ability of WMIHC and its subsidiaries and any future subsidiary, to utilize their NOLs and other tax carry forwards to reduce taxable income in future years may be limited for various reasons, including if projected future taxable income is insufficient to recognize the full benefit of such NOL carry forwards prior to their expiration. There can be no assurance that we will have sufficient taxable income in later years to use the net operating loss carry forwards bef
Quartalsbericht von eben:
The IRS could challenge the amount of our net operating loss carry forwards.
The amount of our net operating loss carry forwards has not been audited or otherwise validated by the IRS. The IRS could challenge the amount or timing of our net operating losses, which if successful, could significantly reduce a portion or all of our net operating loss carry forwards. In addition, calculating whether an ownership change has occurred, for tax purposes, is subject to inherent uncertainty, both because of the complexity and ambiguity of Section 382 of the Code and because of limitations on a publicly-traded company’s knowledge as to the ownership of, and transactions in, its securities. Therefore, the calculation of the amount of our utilizable net operating loss carry forwards could be changed as a result of a successful challenge by the IRS or as a result of our learning of new information about the ownership of, and transactions in, our securities.
Nebenbei: wie erwartet, NICHTS konkretes zu kommenden Akquisitionen.
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| Wertung | Antworten | Thema | Verfasser | letzter Verfasser | letzter Beitrag | |
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