I did some research on this company and it appears this company won't have to pay taxes on any of their newly generated profits as they have $200 million in NOL carryforwards. That is huge considering their market cap.
A small item - NOL carryovers can only offset 90% of AMT taxable income, so AI is looking at a 2% Federal tax rate going forward. If it were to re-elect REIT status, its tax rate would be zero. Unless Washington fixes the tax situation, the shareholders' tax on dividends from a C corporation or a REIT would be taxed the same. The only benefit to the NOLs that I can see is that they allow AI to accumulate income if it decides to do so. It could not do that as a REIT without paying some tax. I don't know enough about AI to estimate the state tax impacts, so those might be an issue favoring C Corp vs REIT status.
I spoke with the company and you are correct. Some of these NOL carryforwards, ($230 million) will begin to expire and will be used to minimize taxes in the future up through 2027. have been a long time holder and will continue to hold unless circumstances dictate other action.