Mr Cooper Group Inc (COOP)

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Former equity might get contingent rights

For federal income tax purposes, this generally is treated no
differently than if the plan distributed the assets directly to the creditors, and such assets were
subsequently sold by the creditors themselves. (See Section VIII.C hereof.) Significantly, the tax
treatment to each creditor with respect to the receipt of a Liquidating Trust Interest depends on the value
of the Liquidating Trust Interest received and on the Creditor’s or equityholder’s individual
circumstances. For example, the holders of Common Equity Interests, and the holders of Dime Warrants
(if they are determined to hold Equity Interests that are pari passu with the Common Equity Interests,
rather than Claims), would be considered to receive a contingent right to distributions of Liquidating
Trust Interests, which right is (presumably) of little or no current fair market value and, thus, would have
no real risk of taxable income regardless of their individual circumstances.