Depending on how they construct whatever AFFY becomes the NOL should become an off-set to all gains before taxes kick back in. This shouldn't matter whether it is a buyout (built into the share price for the acquisition) or a Royalty Trust...So YES there is $600 million in a "residual" asset in the NOL as long as AFFY is reconstituted in some form...
Folks, I did some google search for Royalty Trust, if you own the trust the Losses of the trust are like Your personal Capital loss and year end this could be written off.
I'm pretty sure many of the funds which bought the shares 4-5 weeks back (45 MLN shares) did this on this basis alone to get a huge payout. All these funds have huge income and this will be a boon for them to write off.
Folks this is getting very interesting though, with Brenner doing a restructuring (restructuring of what??) this is what folks. We will wait.
The share PPS will be worth 4-5 just with this alone and on top of it return of Omontys.