Mr Cooper Group Inc (COOP)

[newflow]

"ALREADY REGARDED"
https://s1.q4cdn.com/275823140/files/doc_downloads/irw/IRS_forms_8937/Mr.-Cooper-Group-WMI-Liquidating-Trust-Disputed-Equity-Escrow-distributions.pdf

PAGE 4
In general,distribution of cash from liquidating trust to liquidating trust beneficiaries will not be separately taxable since such beneficiary is "ALREADY REGARDED" for federal income tax purposes as owning the under lying assets......

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https://www.sec.gov/Archives/edgar/data/933136/000090951812000087/jg02-2712_8ke22.htm

PAGE 239
"ALREADY REGARDED"
The U.S. federal income tax obligations of a holder with respect to its Liquidating Trust Interest are not dependent on the Liquidating Trust distributing any cash or other proceeds. Thus, a holder may incur a U.S. federal income tax liability with respect to its allocable share of Liquidating Trust income even if the Liquidating Trust does not make a concurrent distribution to the holder. In general, other than in respect of cash retained on account of Disputed Claims and distributions resulting from undeliverable distributions (the subsequent distribution of which still relates to a holder’s Allowed Claim), a distribution of cash by the Liquidating Trust will not be separately taxable to a Liquidating Trust Beneficiary since such beneficiary is already regarded for federal income tax purposes as owning the underlying assets (and was taxed at the time the cash was earned or received by such Trust). Holders are urged to consult their tax advisors regarding the appropriate federal income tax treatment of any subsequent distributions of cash originally retained by the Liquidating Trust on account of Disputed Claims.
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Page 2
https://www.irs.gov/pub/irs-wd/202003003.pdf
"Trust provides that the trustee of Trust shall file tax returns as a grantor trust pursuant to
§ 1.671-4(a)of the Income Tax Regulations. "
We submitted W-9 as other direct owners of the trust as stated in treasury regulations IMO.
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THE REASON FOR COLLECTING W-9 ----- 1.671-4(a)
https://www.law.cornell.edu/cfr/text/26/1.671-4
IMO.
(b) A trust all of which is treated as owned by one or more grantors or other persons -

(1) In general. In the case of a trust all of which is treated as owned by one or more grantors or other persons, and which is not described in paragraph (b)(6) or (7) of this section, the trustee may, but is not required to, report by one of the methods described in this paragraph (b) rather than by the method described in paragraph (a) of this section. A trustee may not report, however, pursuant to paragraph (b)(2)(i)(A) of this section unless the grantor or other person treated as the owner of the trust provides to the trustee a complete Form W-9 or acceptable substitute Form W-9 signed under penalties of perjury. See section 3406 and the regulations thereunder for the information to include on, and the manner of executing, the Form W-9, depending upon the type of reportable payments made.