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A 41-page cross-cut walking Berkshire Hathaway, Apple, Microsoft, Koch Industries, Lyft, and Meta through the six-source-of-funds framework. Sourced numbers traced to 10-K filings. The thesis: at sufficient scale, every operating company starts allocating like a PE firm, whether or not it admits it.
The framework and only the framework: what an NOL is and why it is not the deferred tax asset, the TCJA 80% cap, the §382 ownership-change limitation with NUBIG/NUBIL and the §382(l)(5) bankruptcy exception, state non-conformity, why the GAAP loss is not the NOL, temporary and permanent differences, ASC 740 valuation allowances, how the attribute runs through the cash flow statement, credits, and the corporate alternative minimum tax. It carries no company balance, no share price, and no equity value — which is exactly what makes it durable. Free to read, free to print, free to pass along. Readable in full on its own page, or downloadable as a PDF — no signup either way.
A 31-page cross-cut walking Lyft, Cleveland-Cliffs, SNAP, and General Motors through the §382 ownership-change limitation, valuation allowance dynamics, and the book-vs-tax bridge that most sell-side models miss. Sourced to each company's 10-K and recent 10-Q, with every point-in-time figure carrying its own measurement date.
New to net operating losses? Read Part One first. This Brief opens on four live company positions and reads their income-tax footnotes at practitioner speed. It does not stop to define an ownership change, explain why the GAAP loss is not the tax loss, or walk the entries that carry a deferred tax asset from the return to the cash flow statement. Part One does all of that, free, on the page or as a PDF.
What pro sports teams can actually do to reduce their players' state tax bills — the jock-tax mechanics, the CBA disparity between MLB, NBA, and NFL, and the legally defensible levers a front office can pull without inviting a challenge from a state department of revenue.
MLB players file bankruptcy at one-third the NFL rate. The reason is structural — specific collective-bargaining provisions that route athletes toward second careers, second businesses, and second acts instead of post-career drift.
The numbered series was reset in May 2026. The inaugural Issues 01 (OBBBA exemption) and 02 (buy-sell audit) were short practitioner observations rather than the cross-cutting, multi-company Briefs the Library uses the word "Brief" to mean. They have been republished under their original titles on the.
Going forward, a Brief is a 15-40 page synthesis across five or more companies with sourced numbers and a methodology note. Issue 03 (MLB CBA, four leagues compared) sets the standard. The Private-Equity Brief and the Net-Operating-Loss Brief sit alongside it as Special Briefs. See how the four shelves fit together →
A Brief is a cross-cutting synthesis across four or more companies, 15-50 pages, with sourced numbers traced to filings and a methodology note. The Private-Equity Brief walks six PE firms through the six-source-of-funds framework. The Net-Operating-Loss Brief walks four companies through the §382 limitation. Issue 03 walks four leagues through the post-career bankruptcy data. Each was ready when the cross-cut was complete, not when the publishing calendar said so.
For the practitioner moment-in-time observations — the OBBBA play, the §1202 stack, the 13-week cash forecast — see the.