NOL´s
the 14.45B figure is from EC's closing arugment p.p. slide for plan 6.5. [flow posted in one of his recent thread as "NOLES --- 6B"].
it specifically contains,
Assets transferred to JPMC and the FDIC are as follow:
1.Anchor Saving Litigation: 335M
2.Pre-bk Cap. Contribution: 6.5B
3.TPS collaterals: 4B
4.Tax refunds: 3.5B
5.VISA shares: 115M [140M - 25M]
Total: 14.45B
I was wrongly characterizing the 14.45B as NOLs. But actually they are cap. contribution[loss] under the GSA for tax purpose.
So far we know that we have 5.5B NOLs by the IRS ruling or 26B cap losses upon the abandonment of WMB stocks. The choice of the two depends on the need of the newco to offset the profits [i.e., type].
I believe your suspicion of the manipulation of the tax benefits is legitimate.