TAX IMPACT ANALYSIS:

In-Court / Out-of-Court Analysis

A decision-making tool to mitigate risk and find liquidity by evaluating:

• Immediate cash tax leakage
• Go forward tax efficient out-of-court structure
• Impairment of tax attributes

IN-COURT OPTION / 1ST DAY MOTION:

Trust Fund Tax Motion
Equity / Debt Trading Orders

A&M Taxand is laying the foundation to protect attributes & preserve the tax structure post-emergence by running analysis, substantiating trading orders, monitoring trades, etc.

PRE-FILING: IN-COURT OPTION / 1ST DAY TAX MOTION

• Evaluate the state tax effects of Sec. 382, Sec. 108 etc.
• Evaluate the state tax effects of asset sale v. reorganization
• Participate in first day calls to ensure the proper state tax information is ascertained for the Tax Motion
• Assist with the evaluation of tax providers subject to the OCP motion
• Quantify the materiality of current state tax audits and how those amounts may impact liquidity models

RESTRUCTURING
TAX SERVICES

A&M Taxand helps use the protected liquidity and create future value by:

• Implementing a tax efficient structure
• Launching Fresh
• Start Accounting
• Providing Transaction Cost Analysis (TCA)
• Running 382 Studies
• Managing go forward compliance and provision
• Leveraging Tax Sharing Agreements (TSA)

A&M helps use the protected liquidity and create future value by:

• Managing tax compliance
• Managing state tax proof of claims process and audit notifications (including objections, if necessary)
• Managing Voluntary Disclosure Agreements (VDA) process by negotiating VDA’s to minimize penalties and interest and ensure compliance prospectively

Historic Calcs.

382 / L5 / L6 Analysis

Inside / Outside Basis

Cash Tax Modeling

Cancelation of Indebtedness Income (CODI)

Analysis