Certain non corporate U.S. Holders (including individuals) are generally eligible for preferential rates of U.S. federal income taxation in respect of long term capital gains (i.e., gains on a Security held for more than one year).
If escrows were to receive these funds it should be taxed as cap gains since held since 2012. 15-20%.
Note HRC plans to raise cap gains to 45% so this needs to get done quickly. $5B will pay 1/2 par but not a bad start. We shall see if this happens.