ACCOUNTING & VALUATION: Understanding Net Operating Losses and Their Valuation
Background
Net
operating loss (NOL) arises when a company’s tax deductible expenses exceed its
total taxable revenues for a particular year. It allows a company to set off
its positive pre-tax profits (calculated as per the taxation rules) with the existing
NOL balance. This rule for adjusting the NOL balance varies across countries.
How to value NOLs?
NOLs are
valued by aggregating the discounted value of the company’s tax savings arising
due to the adjustment of the pre-tax profits with the existing NOL balance. The
valuation of NOLs depends on whether a company would be able to generate
sufficient profits in the coming years to set off its existing NOL balance. For
instance, in Illustration 1 below, Company A generates profits in the future
years, which are sufficient to set off its loss accrued during year 1. This
allows the company to generate total tax savings of roughly USD 10 Mn over the next
3 years. Consequently, the company’s NOL is valued at USD 8.1 Mn, assuming a
tax rate of 35% and a discount rate of 8%. Company B, on the other hand, is a
loss making company, and assuming that the company doesn’t generate positive
profits in the coming years, it doesn’t derive any tax saving. In fact, if
there is any concern on the future profitability or the going concern basis of the
company, the company’s auditor may suggest to reduce/remove the NOL build up in
the balance sheet in the form of DTAs (Deferred Tax Assets).
NOLs per se
do not impact the financials or income statement adjustments. The benefit from
NOLs is reflected in the form of lesser cash taxes paid by the company, which
gets recorded in the cash flow statement. The profitability of the company does
not change due to the buildup or usage of NOLs.
Overall, NOLs
represent a storehouse of value in the form of future tax savings for any
company. Needless to say, the company should have future profitability to earn
any benefit from them. An analyst should carefully consider these when valuing
a company and adjust the NOPAT in their DCF calculation.
Carry-Back and Carry-Forward – What is the
difference?
According to
the guidelines provided by IRS regarding the corporate taxation rules in the
United States, NOLs can be carried back and set-off 2 years prior to the
company’s fiscal year, or can be carried forward for a period of up to 20 years
(Method 1). Businesses can also elect to waive the carryback period and instead
carry the loss forward for up to 20 years (Method 2). However, ideally, it is
better to use Method 1 for adjusting NOLs rather than the latter, since it
results in higher present value of savings, although the absolute amount of
total savings remains same in both cases. A practical example clarifying this
issue has been shown in Illustration 2 below:
Assuming
that year 5 is the current fiscal year in Illustration 1 above – If the company
uses Method 1 for adjusting its NOL balance with the pre-tax profits, then it
can carry back and set off its NOL with the pre-tax profits in year 3 and year
4 and the remaining balance can be carried forward and adjusted in future years
like year 6 and year 7 and partially in year 8. However, if the company uses Method
2, then it can set off its NOL balance with the profits in future years.
Although both the methods produce the same amount of gross savings of USD 10.5
MN, the net present value of these savings vary due to timing differences.