The following is the proof that equity interest, both preferred and common interest of former debtor will be cancelled on ED,3-6-2012 and will be rewarded and held by Plan Trust with new common share of the reorganized debtors according to relative priority and entitlement.
GRANTOR AND BENEFICIARY STATEMENT
LEHMAN BROTHERS HOLDINGS INC. PLAN TRUST
277 PARK AVENUE, 46TH FLOOR
NEW YORK, NY 10172
FOR THE TAX YEAR ENDED DECEMBER 31, 2017
Background
On December 6, 2011, the United States Bankruptcy Court for the Southern District of New
York entered an order confirming the Modified Third Amended Joint Chapter 11 Plan of
Lehman Brothers Holdings Inc. (“LBHI”) and its Affiliated Debtors (the “Plan”). On March 6,
2012 (the “Effective Date”), the Plan became effective.
The Plan provided for the creation of the Lehman Brothers Holdings Inc. Plan Trust (the “LBHI
Plan Trust”). Pursuant to the Plan, LBHI and certain individuals designated pursuant to the Plan
as trustees (the “Trustees”) entered into a trust agreement (the “Plan Trust Agreement”),
effective as of March 6, 2012, establishing the LBHI Plan Trust.
Pursuant to the Plan, as of the Effective Date, all existing shares of common stock and preferred
stock issued by LBHI were cancelled, and LBHI issued one new share of common stock (the
“Plan Trust Stock”) to the LBHI Plan Trust, which holds such share for the benefit of such
former stockholders of LBHI consistent with their former relative priority and economic
entitlements. The Plan Trust Stock comprises the sole asset of the LBHI Plan Trust, and the
beneficial interests in the LBHI Plan Trust are nontransferable.
Liquidating Trust Status
For U.S. federal income tax purposes, the LBHI Plan Trust is treated as a “liquidating trust”
taxable as a “grantor trust” of which the former LBHI stockholders are regarded as the grantors.
Each former stockholder of LBHI that is a beneficiary of the LBHI Plan Trust is treated for U.S.
federal income tax purposes as a direct owner of the underlying assets of the LBHI Plan Trust
(i.e., the Plan Trust Stock) in accordance with its former relative priority and economic
entitlements as a stockholder.
If you own former LBHI priority or common share, the above is your assurance of reward. (IMHO)
