And if GM and Citibank and AIG need tax relief? We can-a do that for youse!
“Can the Treasury Exempt Its Own Companies from Tax? The $45 Billion GM NOL Carryforward,” and the authors’ answer is No.
“Treasury solved this problem by issuing a series of "Notices" in which it announced that the law did not apply. On its terms, § 382 states that the NOL limits apply when a firm's ownership changed. That rule, the Treasury declared, did not apply to itself. Notwithstanding the straightforward and all-inclusive statutory language, GM would be able to continue to use its NOLs in full after the Treasury sold its stock.
The Treasury had no legal or economic justification for these Notices, which applied to Citigroup and AIG as well as to GM.What you see in Obozo & Co. is the old "L'etat? C'est moi." of Louis XIV.
How's that cake?