A Jewish refugee delegation, including my father, went to the Vilnius Japanese vice consul, Chiune Sugihara, for these transit visas. Sugihara wired … - Sam Zell

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A Jewish refugee delegation, including my father, went to the Vilnius Japanese vice consul, Chiune Sugihara, for these transit visas. Sugihara wired Tokyo three times for permission to help the refugees, but was denied each time. The vice consul was a Japanese career diplomat, but he had also been raised in a middle-class samurai family. And part of the code of the samurai is benevolence and mercy, and appreciation and respect for life. Despite the risk to his career and his family, Sugihara ignored his direct orders and decided to do as much as he could. For the next month, he and his wife barely stopped to eat or sleep as they wrote out thousands of transit visas. My family was among the six thousand Jews Sugihara saved — the Sugihara Survivors.

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Around the same time, Congress passed the Economic Recovery Tax Act. Among other things, it extended the life of net operating loss carry-forwards (NOLs) from seven to fifteen years. NOLs allow companies to offset their current year’s taxable income with past losses, thereby reducing current tax liability. The goal of the act was to help struggling companies recover and to enable their shareholders to benefit from the prior losses. We took a look at all of the public companies with large NOLs and found something surprising. These companies had virtually no change in share price as a result of the new legislation. The market was overlooking the significant value added through the extended life of NOLs. That presented us with an enormous opportunity to gain control of those NOLs and create holding companies for businesses whose profits would be shielded. If a company was trading at $3 a share for a total enterprise value of $45 million and it had $350 million in NOLs, we knew we could create profits that were sheltered and convert those NOLs (which were valued at $0) to roughly $100 million of cash, or 25 cents on the dollar over time. And that’s just what we did.

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