Sunday, August 22, 2021 12:38:30 PM
* WMIH / now trading as "COOP" Is Currently A Stand Alone and Functioning NasDaq Traded Entity' ... Currently Being Managed By The Current BOD's ... period' ...
* The WMI Reorganizations Plan's, "wmi-lt", Is Done, and Financially Deplete' ...
* Original Interest Withheld, Yet Still Owed, Will Be Returned per INDIVIDUAL Issued ESC Cusip ... there never was going to be any 75/25 inclusive' ratios of return' ...
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"Thanks" Sunshine, Yes, You Understand' ...
This PLR (follows-next link) is the most important find next to AZ/Ron/Boarddork's collective MBS DD and Gov's sharing of the Receivership's balance sheet evolution from INCEPTION to the current WIP one.
https://www.irs.gov/pub/irs-wd/202044002.pdf
Namely, this is the REVELATION/CONFIRMATION of our long-awaited $Recovery (albeit still ridiculed to date) and HOW the return is handled as the WMILT, we all get to know for the past 9 years, is DONE and EMPTY and upon 350 closure, there is no more SEC requirement to abide by in terms of public disclosure.
Rosen or his cohort whoever penned the this BK plan is well verse in SET THEORY. It certainly has stumped me until the APPEARANCE of this PLR ( THANKS to NEWFLOW & VITELLOM for sharing).
It's so cleverly laid out that it's no shame for folks WHO still cannot see the applicability of this PLR to WMI, the emerged entity being nothing BUT a TRUST that is NOW in its last act = completing its final task - liquidating and distributing before disappearing for good.
However, there is no need to get that "technical" ( for those who wants to, it'd be fun to try) as an equally adequate explanation, namely the following simple common trust knowledge would suffice:
"When a trust dissolves, all income and assets moving to its beneficiaries, it becomes an empty vessel."
So, just ask ourselves a couple of simple questions:
(1) What should happen to WMILT now that it is DONE & EMPTY after the final distribution was made back in early Jan 2020 and all the outstanding litigations have been terminated?
It should have been dissolved, but it's NOT!
(2) Before us is a PLR request ( template as some calls here) submitted to IRS for a ruling to AFFIRM the requested "TRUST" be considered a liquidating trust in term of TAX treatment that can be filled out comfortably with the WMI dates and events that were happening at the time of the request & SUBSEQUENT correspondence.
Do we all need to SPELL all the "guts" out to enable a conclusion? ( I don' think so because there are quite a few astute folks here on this board...just stay silent to avoid unnecessary confrontation/challenge)
(3) What is the emerged WMI?
According to the court filing, attempt(s) to contact "WMILT" to resolve the UW 1% crap were unsuccessful as the initial response was " we are no longer representing WMILT" ( not a verbatim quote but the gist of it for those WHO wants to be ANAL retentive) which prompted to list WMI, Inc & WMILT as defendants and ultimately settled as WMI liquidating trust.
However, this is NOT the same WMILT as we know for the past 9 years for reason I already alluded to on (1). The emerged WMI is using the SAME EIN for tax treatment purpose and sought and received IRS "blessing".
(4) What other confusions can be eliminated from this PLR?
(i) Since it is a trust, there'd be NO LTI but only beneficiaries and in our case, our Escrow cusips in our brokerage accounts.
Again, the "liquidating trust" is a common nomenclature often used OUTSIDE of BK by a trust/fund and recognized/accepted by IRS for the purpose to help expedite the liquidation of the entity, and allow the beneficial owners to recognize gain or loss and to receive proceeds in an orderly manner.
(ii) There will be NO new corporate entity to be formed, private LLC or partnership or whatever one proffers.
(iii) " All income and assets( reside in the trust) moving to its beneficiaries" is its FINAL ACT, hence the CASH & In-Kind Distribution to appear in our brokerage accounts before becoming EMPTY.
(iv) The "TRUST" will be dissolved only after it "MOVED all the incomes & assets" to our escrow cusips containing brokerage accounts. ( Split T - no need to spend the $ 20 in future but thanks that you did).
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"it is what it is", ... and' ... its all good ... GO COOP' ... while we wait for our INDIVIDUALIZED ESC Cusips to be utilized' ...
~ Know WHAT "YOU" Own ~
~ Watch The NewCo, "COOP", It Is The "Tell" ~
just sayin' :)
AZ
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