The Liquidating Trust files income tax returns in those states in which it determines it has a filing obligation.
The Liquidating Trust provides Tax Worksheets for Beneficiaries for each of the states in which the Trust files an income tax return via postings on the Trust’s website at:
However, there can be no assurance that this will be the case.
The Liquidating Trust owns all of the stock of two US corporations – RFC Foreign Equity Holding Co. – that owned the stock of several foreign corporations.
You must designate a broker, bank or other financial institution with which you maintain a securities account to receive your Units on your behalf.
You may email the Trust at [email protected] request a form on which to provide your securities account information or access such form on the Trust’s website here.
A Fellow of the American College of Bankruptcy, David has frequently been ranked among leading U. He is a graduate of Cornell University and the Columbia University School of Law. He joined UBS as the chief operating officer of the Investment Bank in March 2012. Molinaro was appointed to the executive committee in 2001 and served as executive vice president of The Bear Stearns Companies Inc. He received a bachelor’s degree in business administration from St. Prior to his role as an advisor, he served as Executive Vice President and Chief Portfolio Officer for the company. Sonkin was responsible for the oversight of MBIA’s 8 billion global portfolio of insured municipal, corporate and structured finance credits, including, all workout, restructuring and litigation related remediation activities. and international workouts and restructurings, corporate reorganization and insolvency matters, and has served as a court appointed examiner. Sonkin has played a significant role in complex structured finance, corporate, infrastructure, utility, healthcare and insurance company reorganizations and served as chief counsel in the rehabilitations of Mutual Benefit Life and Confederation Life Insurance (U. Assets that are held by the Debtor entities under these circumstances are referred to as assets held in bailment.The Liquidating Trust Agreement provides that the Liquidating Trust was “established for the purpose of liquidating and distributing the Liquidating Trust Assets in accordance with Treasury Regulations Section 301.7701-4(d), with no objective to continue or engage in the conduct of a trade or business, except to the extent reasonably necessary to, and consistent with, its liquidating purpose….” The Trust Agreement further provides that “no part of the Liquidating Trust Assets shall be …used or disposed of in furtherance of any trade or business.” Consistent with these provisions, and in light of the nature of the Liquidating Trust’s assets, the Liquidating Trust does not believe that to date it has recognized any income that would constitute trade or business income (or unrelated business taxable income or income that is effectively connected to the conduct of a trade or business in the United States, though such characterizations may depend in part on each Unitholder’s unique tax position) , and it does not anticipate that it will do so in the future.A Beneficiary with a basis difference should consult its tax advisor as to whether and how any adjustments should be made as a result of such differing basis to the per Unit Trust items of taxable income and loss as reported by the Trust for the periods that such Beneficiary holds its Units.In general, that may depend, in part, on the determination as to which Trust assets or liabilities the basis differential is attributable and how to calculate the recovery of basis that is allocable to multiple assets of the same class, such as the litigation claims.CAP RE of Vermont, LLC (“Cap Re” ) is a capt ive insurance company incorporated and licensed under the laws of the State of Vermont.Cap Re, which is taxed as a C corporation, was owned by GMAC Mortgage, LLC and is now owned by the Liquidating Trust.Effective as of January 15, 2014, the Liquidating Trust contributed those properties (as well as certain interests in mineral rights that have only nominal value) to Res Cap Securities Holdings Co., a wholly-owned U. It is contemplated that the corporate subsidiary is a United States real property holding corporation within the meaning of section 897 of the U. As of December 31, 2017, Res Cap Securities Holdings Co owned approximately 20 properties in 15 states.The Trust is a liquidating trust for federal and, if applicable, state income tax purposes.He is the founder of North Country Capital, an investment and advisory firm where he currently serves as President. Doheny served as a Managing Director and helped lead the Distressed Products Group of Deutsche Bank Securities Inc. Prior to Deutsche Bank, he was a bankruptcy attorney in the corporate reorganization groups of Orrick and Kelley Drye. Doheny currently serves on the boards of YRC Worldwide Inc, Affinity Gaming, Arcapita Inc (RA Holdings) and Eastman Kodak Inc. After his time at Price Waterhouse, he served as a Senior Managing Director at FTI Consulting. Weber has served on the Contra Costa Civil Grand Jury, performed occasional independent consulting projects and assumed board/trustee positions. Weber currently serves on Board of Directors of winery Truett Hurst, Inc., and chairs the audit committee.Previously, he was a Managing Director and Co-Head of Special Situations Trading at HSBC Securities, where he headed up credit research. Doheny was a portfolio manager at Fintech Advisory Inc., a hedge fund focusing on undervalued securities and turnarounds in the U. He received a BA from Allegheny College and a Juris Doctor from Cornell Law School. The Res Cap Liquidating Trust was established in December 2013 under the Second Amended Joint Chapter 11 Plan of Residential Capital, LLC, et al.