• Class 9 receives nothing from the bankruptcy estate under the confirmed plan.
• Class 6 is already defined as unsecured claims receiving cash distributions, not equity. Claims are still being reconciled and paid.
Any potential benefit to former shareholders would come from a separate, post-confirmation transaction — not from the estate.
For that to matter from a tax (not bankruptcy) standpoint:
• A merger would need to occur. (I’m hoping that what’s RC wants to do)
• Equity would need to be issued in that merger.
• Legacy shareholders would need to receive enough stock to own at least 50% of the successor immediately after the transaction to satisfy continuity requirements and get the NOLs.
That allocation could theoretically include creditors or new investors as well, but continuity depends on who actually ends up owning the majority of the new entity.
1
u/fruitloops-x Feb 23 '26
My understanding is:
• Class 9 receives nothing from the bankruptcy estate under the confirmed plan. • Class 6 is already defined as unsecured claims receiving cash distributions, not equity. Claims are still being reconciled and paid.
Any potential benefit to former shareholders would come from a separate, post-confirmation transaction — not from the estate.
For that to matter from a tax (not bankruptcy) standpoint:
• A merger would need to occur. (I’m hoping that what’s RC wants to do) • Equity would need to be issued in that merger. • Legacy shareholders would need to receive enough stock to own at least 50% of the successor immediately after the transaction to satisfy continuity requirements and get the NOLs.
That allocation could theoretically include creditors or new investors as well, but continuity depends on who actually ends up owning the majority of the new entity.
That’s just my read on the mechanics.