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Technology Stocks : Loral Space & Communications
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To: Valueman who wrote (2232)3/13/1998 2:14:00 PM
From: Snake  Read Replies (1) of 10852
 
Re: ONSI tax loss carryforward.

Typically (and in almost all cases), with a change in control of a loss company (company with tax loss carryforwards), the loss can only be used by the company that generated it (i.e. Orion). This will dictate the book treatment also.

The rule under 382 of the Internal revenue Code was intended to curb the practice of buying companies with huge loss carryforwards and offsetting them with other companies earnings. I would also expect that Orion's current losses will not offset any of Skynet's or SS/L's income due to the entity structure. The companies tax rate for books will be below the 40% federal/state rate once ONSI turns profit due to the utilization of these carryforwards.
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