GREY:TBTEF - Post by User
Post by
cigarbutt1on Apr 01, 2017 1:52pm
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Post# 26063041
Re: Canadian development expense...
Re: Canadian development expense... Expertchoc,
I respect your opinion and the time spent but I have spent some time also filling this knowledge hole lately. Somehow, I hope you are right. But.
I understand that Oldfart provided useful info here but his last related message end up with a question mark.
Would like to hear Kasparovisme on this but my take now is that the purchaser, in buying essentially all oil and gas "properties", was able, with the Receiver's assent, to transfer the associated tax pools (unused expenses which likely comprised most/all of available and useful tax pools). The Successor rules seem to treat a share sale and a substantially all assets sale on the same basis ie in substance, the properties changed owner and the tax pools followed.
Yes, with the purchase price allocation (detailed form not available now to outside of insiders), assets have been allocated a new value on the balance sheet of the buyer but, if anything, my take is that the tax pools available became lower in value as some assets purchased were stepped-up on the purchaser's books in order to maximize tax deductible expenses going forward. (Compare Q2 financials with your evaluation of purchase price).
I continue to think that the value of the pools to be around 10-20 millions but that value was likely reflected in the purchase price.
My take, for what it's worth.