AFAICT, that $450K is refundable and transferable. IOW, if you make $0 in year two and have expenses of $0 in year two, you'd get a tax refund of $100K because $200K of your expenses from year one would be applied to year 2.

And it's transferable -- if your company fails, there are companies out there that will buy the rump of your company to realize the unrealized tax refunds.

Which is why it's usually fairly straightforward to get a factor loan to pay those $450K in taxes -- it's backed by an asset.

Factor loans are usually expensive with a high interest rate. Because you can get a factor loan, the taxes are not going to immediately bankrupt the company in the short term, but the high interest rates are going to hurt in the long term.

Not a lawyer nor an accountant. Not even an American.