Twin Butte Energy Ltd TBTEF

RE:Tax pools successor corporation

[cigarbutt1]

Never thought I would go after this aspect so much, but interesting...
Thanks for all the info.
Maybe this will amount to nothing but who knows for sure.

So far,

-This has been an asset sale.
-In theory, the buyer and the seller agreed on a detailed allocation schedule for all O+G assets.(which is not disclosed at this point)
-They seem to agree on a joint election type of tax filing (thank you Oldfart) for the maximum allowed under the circumstances defined by tax rules.
The buyer meets the successor rules that entitle them to use the "acquired" deductions over time.
-The last three above items allow the buyer to "optimize" the use of the capitall carryforward component of the tax pools.

So far the well seems to be dry.

BUT

My understanding is that the above does not allow full use of the capital tax pools because, given how the PSA is geared to an asset sale, the purchase price allocation has to be tied to present fair value assessment of the assets. My take is that the buyer, without a share acquisition will lose a significant? part of the capital tax pools.
My understanding also is that going along with an asset purchase, the buyer foregoes the vendor's non-capital carryforward and perhaps other deductions such as certain investment tax credits.

There just might be enough value for the buyer in the remaining tax pools (that will disappear with the shell otherwise) to go after the shares themselves.
Buying a liquidating frim through shares has disadvantages that can be mitigated by going through other steps supervised by the Court.

The coming secured distribution has got me thinking.

If there is more to come, I am ready to listen.