Jul. 4 at 3:37 AM
$SICP In addition to monetizing its other assets (SEN, Diem, potentially legal claims, etc etc), reorganized Silvergate intends to also preserve and monetize its NOLs of around
$3B. According to the information reorganized Silvergate provided to OTC, reorganized Silvergate wholly owns its subsidiary Silvergate Group (formerly known as Silvergate Bank). This subsidiary could be used for a so-called reverse triangular merger.
"In a reverse merger (often structured as a reverse triangular merger), the acquiring company merges into a subsidiary of the target company (reorganized Silvergate).
- The result: The target company (the one with the NOLs) becomes the parent company.
- The tax view: From the IRS's perspective, the original owners of the target company still hold most of the shares in the parent company. Because a massive ownership shift did not happen, the target company's NOLs are preserved."
For additional information, see comment attached to this post.
