Losses on income account cannot be used to offset profits on...

Losses on income account cannot be used to offset profits on capital account. That's revenue law 101. I could be wrong. Also I am assuming the losses they have accumulated on the balance sheet are trading losses and not capital losses. On the other hand why raise the tax question if there is no tax payable because of the accumulated losses. I'm not an expert. This is a complex area. I may be wrong. I'm just guessing.